Jane Doe I, as Legal Guardian of the Person and Estate of Jane Doe II, an Incapacitated Adult v. Carmel Operator…

Summary

The Indiana Supreme Court held that Certiphi, a nonsignatory to the residency agreement, could not compel arbitration because it was neither an agent and intended third-party beneficiary of the agreement nor entitled to equitable estoppel. The court reaffirmed that Indiana equitable estoppel requires lack of knowledge, reliance, and prejudicial change in position, and declined to adopt alternative arbitration-by-estoppel theories based on interrelated claims or judicial efficiency. The court reversed as to Certiphi but affirmed the order compelling arbitration of the claims against the other defendants.