Jacob Benson v. Casa De Capri Ent

Summary

The court answered the Ninth Circuit's first certified question no, holding that an insurer cannot use direct benefits estoppel in a garnishment proceeding to bind a judgment creditor to the terms of an insurance contract. Arizona's statutory garnishment scheme requires the trial court to resolve all factual and legal issues, so a common-law estoppel doctrine cannot compel arbitration or otherwise displace that scheme. Because the answer to the first question was no, the court did not reach whether direct benefits estoppel would bind the judgment creditor to the policy's arbitration clause.