Catherine Farrell v. Twenty-First Century Insurance Company

Summary

The court affirmed summary judgment for the insurer because the parties never formed an enforceable written agreement to arbitrate. Their correspondence showed disagreement or nonresponse regarding every proposed arbitration term, and any oral understanding could not cure the absence of a written agreement. The court also held that any factual dispute about the parties’ intent was legally immaterial because the purported agreement was not validly formed in writing.