Earlier this month, an appellate court in California issued a written opinion in a personal injury case involving the enforceability of an arbitration agreement that an employer signed when renting out a U-Haul truck. The case is important for potential Maryland truck accident plaintiffs to understand because it addresses the enforceability of arbitration agreements, which commonly are at issue in many personal injury cases.
The Facts of the Case
The plaintiff was working for his employer, delivering some massage chairs to a customer. To help the plaintiff make the deliveries, his employer rented a truck from U-Haul, the defendant. Contained in the rental agreement signed by the employer was a clause agreeing to submit any claim arising from the use of the truck to binding arbitration. The employer signed the rental agreement, but the plaintiff did not.
On the way to make the delivery, a tire blew out on the truck, and the plaintiff was seriously injured as a result. Notwithstanding the arbitration clause contained in the rental agreement, the plaintiff filed a personal injury lawsuit against U-Haul. In defense, U-Haul claimed that the plaintiff’s claims were barred because he was required to submit them to arbitration, pursuant to the rental agreement.
The Court’s Analysis
The trial court denied U-Haul’s motion, and U-Haul appealed. On appeal, the court affirmed the lower court’s denial of the motion. The court explained that, in general, arbitration agreements are given effect when they are valid. Additionally, the accident involving the plaintiff was exactly the type of claim covered under the arbitration clause. However, the court also explained that a party cannot be forced to arbitrate a claim unless he has agreed to do so.
Here, it was undisputed that the plaintiff did not sign the agreement to arbitrate. However, U-Haul argued that the plaintiff should be bound by the agreement nonetheless. U-Haul cited several exceptions to the general rule that a non-signing party cannot be bound by an agreement to arbitrate. For example, U-Haul claimed that the plaintiff was a third-party beneficiary of the contract between his employer and U-Haul, and because of the benefit conferred upon the plaintiff, he should be bound by the agreement. The court disagreed, noting that the plaintiff was not the intended beneficiary of the contract, and any benefit he did receive was ancillary to that of the true beneficiaries because he was merely working as a delivery driver.
Have You Been Injured in a Maryland Truck Accident?
If you or a loved one has recently been injured in any kind of Maryland rental car accident or rental truck accident, you may be entitled to monetary compensation. The dedicated Maryland personal injury lawyers at the law firm of Lebowitz & Mzhen Personal Injury Lawyers have extensive experience representing victims across Maryland, Virginia, and Washington, D.C. Call 410-654-3600 to schedule a free consultation with a dedicated personal injury attorney today.
More Blog Posts:
Maryland Underride Accidents and How They Can Be Prevented, Maryland Trucking Accident Lawyer Blog, published December 19, 2017.
Plaintiff’s Case Dismissed for Failure to Comply with Discovery Deadlines, Maryland Trucking Accident Lawyer Blog, published December 5, 2017.