Beck v. Park West Galleries, Inc

This case requires the Court to consider whether an arbitration clause included in invoices for plaintiffs’ artwork purchases applies to disputes arising from plaintiffs’ previous artwork purchases when the invoices for the previous purchases did not refer to arbitration. We agree with plaintiffs that the arbitration clause contained in the later invoices cannot be applied to disputes arising from prior sales with invoices that did not contain the clause. Each transaction involved a separate and distinct contract, and the facts do not reasonably support a conclusion that the parties intended…