Santich v. VCG Holding Corp.

Citations

• 2019 CO 67
• 443 P.3d 62

Syllabus

The Supreme Court accepted jurisdiction over a certified question of law from the U.S. District Court for the District of Colorado to determine whether there should be an arbitration-specific exception to Colorado's traditionally defined doctrine of equitable estoppel. The Court held that Colorado's law of equitable estoppel applies in the same manner when a dispute involves an arbitration agreement as it does in other contexts. The Court recognized that under Colorado law, equitable estoppel requires proof of four elements—one of which is detrimental reliance. Thus, a nonsignatory to an arbitration agreement can only assert equitable estoppel against a signatory in an effort to compel arbitration if the nonsignatory can demonstrate each of the elements of equitable estoppel, including detrimental reliance.