Washington Mutual Finance Group, LLC v. Bailey

E. GRADY JOLLY, Circuit Judge:

This case requires us to determine the effect of an individual’s illiteracy on the enforcement of an arbitration agreement, which the individual admits he signed, but because of his illiteracy, denies he understood. The district court held that the individual’s illiteracy, coupled with a lack of oral disclosure, rendered the agreement proeedurally unconscionable. We conclude the district court erred and REVERSE.

I

Washington Mutual Finance Group (‘WM Finance”) is a financial institution providing, among other things, consumer credit services. John Phinizee, Willie…