2026-09-12 · Missouri · Courts · Reported — unconfirmed

Reported, and the opinion text was not obtainable. A Missouri Court of Appeals decision is reported to have held that an agreement to arbitrate existed by virtue of owning condominium property subject to declarations that require arbitration — no separately signed arbitration contract needed — and on that basis upheld the confirmation of an arbitration award and the denial of a motion to vacate it.¹

The case is Haack v. Jarvis, No. WD88062, Missouri Court of Appeals, Western District, reported as decided 24 March 2026. The disposition was an affirmance.

Why this is labelled reported

We could not retrieve the opinion. Missouri's judicial websites block automated access, and our account comes from the Missouri Bar's weekly hand-down summary, which carries its own express caveat on every page:

“The Missouri Bar has created headings and summaries for each case. Summaries are not part of the opinions of the Court. They have been prepared for the convenience of the reader and should not be quoted or cited.”

So nothing in this article is an opinion quote, and nothing here is citable as one. We are reporting that the decision exists and what it is reported to hold, because the proposition matters and the question is live for boards and owners.

The reported holding

Among the statutory grounds for vacating an arbitration award is the absence of an agreement to arbitrate. The reported holding is that an agreement existed here because the appellant owned condominium property subject to declarations requiring arbitration of certain disputes, and the disputes so covered included “any matter arising under the declarations” — which govern parking spaces, the subject of the dispute. The circuit court therefore did not err in confirming the award and denying the motion to vacate.

The exact filing date and the rehearing or transfer status are both unconfirmed.

1. The Missouri Bar, hand-down summaries, week of March 20–26, 2026 — identification and holding-at-a-glance for Haack v. Jarvis, No. WD88062 (not quotable) ↩
2. Eikmeier v. Granite Springs Home Owners Ass'n, No. SC101152 (Mo. banc Jan. 23, 2026) — restrictive covenants as private contractual obligations ↩
3. SB 1067 (2026), truly agreed text — § 537.529, RSMo, Uniform Public Expression Protection Act ↩