Olson v. Fca US, LLC

── Olson v. Fca US, LLC ── Court: Court of Appeals for the Ninth Circuit Date: May 21, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT JEFFREY OLSON, No. 24-6527 D.C. No. Plaintiff - Appellee, 2:18-cv-00360- DJC-JDP v. ORDER AND FCA US, LLC, a Delaware AMENDED Corporation, formerly known as OPINION Chrysler Group LLC, Defendant - Appellant. Appeal from the United States District Court for the Eastern District of California Daniel J. Calabretta, District Court, Presiding Argued and Submitted November 21, 2025 San Jose, California Filed April 7, 2026 Amended May 21, 2026 Before: Mary M. Schroeder and Michelle T. Friedland, Circuit Judges, and Karen E. Schreier, District Judge. * * The Honorable Karen E. Schreier, United States District Judge for the District of South Dakota, sitting by designation. 2 OLSON V. FCA US, LLC Order; Opinion by Judge Friedland SUMMARY ** Arbitration The panel affirmed the district court’s denial of automobile manufacturer FCA US, LLC’s motion to compel arbitration. Jeffrey Olson entered a contract with a car dealership to lease a Jeep Grand Cherokee. The lease agreement contained an arbitration agreement with a delegation clause, which stated that questions about the scope of the arbitration agreement must be decided in arbitration. FCA was not a signatory to the lease agreement. Olson was the named plaintiff in a federal class-action lawsuit against FCA, the Jeep’s manufacturer, alleging defects in the headrest. FCA argued that because the arbitration agreement in Olson’s lease agreement with the dealership contained a delegation clause, the district court had no authority to decide whether FCA could enforce the arbitration agreement and instead had to send that question to arbitration. The panel held that FCA cannot compel Olson to arbitrate. With limited exceptions, non-parties to an arbitration agreement cannot enforce the agreement’s terms ** This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  OLSON V. FCA US, LLC 3 against a signatory. Olson never agreed to arbitrate with FCA, and no exceptions to the general rule that only parties to an arbitration agreement can enforce it apply here. The panel rejected FCA’s argument that, even if it cannot enforce the delegation clause in Olson’s arbitration agreement, the court should compel Olson to arbitrate his dispute with FCA. First, the plain language of the agreement does not require Olson to arbitrate any claims with FCA. Second, under California law, FCA cannot use equitable estoppel to enforce the arbitration agreement in Olson’s lease. COUNSEL Mark P. Chalos (argued), Kenneth S. Byrd, Christopher E. Coleman, and Amelia A. Haselkorn, Lieff Cabraser Heimann & Bernstein LLP, Nashville, Tennessee; Stuart C. Talley and Ian J. Barlow, Kershaw Talley Barlow PC, Sacramento, California; for Plaintiff-Appellee. Brandon L. Boxler (argued), Klein Thomas Lee & Fresard, Richmond, Virginia; Fred J. Fresard, Klein Thomas Lee & Fresard, Troy, Michigan; for Defendant-Appellant. 4 OLSON V. FCA US, LLC ORDER The opinion filed on April 7, 2026, is amended as follows: The first sentence on page 10, paragraph two, is amended to read: Henry Schein involved a dispute between a dental equip