Michael-Curry Co. v. Knutson Shareholders
Minnesota Supreme Court
449 N.W.2d 139 (1989)
Michael-Curry Co. (plaintiff) and Knutson Shareholders (defendant) signed a contract with an arbitration clause covering 'any controversy or claim arising out of, or relating to, this Agreement, or the making, performance, or interpretation thereof.' Michael-Curry later sued Knutson in Minnesota state court alleging fraud in the inducement — that Knutson had fraudulently induced Michael-Curry into making the contract in the first place. Knutson argued this claim should not go to arbitration because the clause never specifically mentioned fraud in the inducement. The trial court agreed with Knutson, but the appellate court reversed, finding the clause broad enough to cover the claim, and Knutson appealed.
Whether a claim for fraud in the inducement is subject to arbitration when a contractual arbitration clause is broad enough to comprehend the issue, even without specifically naming fraud in the inducement.