Tonia Land v. IU Credit Union

Summary

The Indiana Supreme Court held that IU Credit Union gave Land reasonable notice of a proposed arbitration addendum, but Land’s silence, inaction, and continued account use did not manifest assent to it. Because no enforceable arbitration agreement was formed, the court reversed the order compelling arbitration and remanded. The court applied ordinary contract-formation principles and treated acceptance by silence as an exceptional circumstance requiring more than an offeror’s unilateral declaration that silence constitutes acceptance.