Georgina Santich, Amanda Livingston, Rebecca Rail, Amanda Gabriel, Casandra Windecker, Gale Raffaele, Adrianne…

Summary

The court answered a certified question by holding that Colorado's traditional equitable-estoppel doctrine applies without an arbitration-specific exception. A nonsignatory seeking to compel a signatory to arbitrate must prove all four elements of equitable estoppel, including detrimental reliance, and the court rejected an alternative rule based solely on interdependent claims or concerted misconduct.