Nonsignatories Bound to Arbitrate

Volato, Inc. v. RPM Flying Ventures, Ltd. arose from a failed fractional-ownership deal for a HondaJet HA-420: RPM agreed under a Commitment Letter (which included a broad arbitration clause) to buy a 12.5% interest for $949,000, but when the transaction fell apart, RPM and several affiliated, non-signatory entities sued Volato, and the trial court compelled arbitration only as to the parties who had actually signed the Commitment Letter.

The Dallas Court of Appeals reversed in part, holding: “Because the nonsignatory plaintiffs seek to enforce rights arising from the Commitment Letter, they are bound by its arbitration agreement. The agreement also clearly delegates arbitrability questions to the arbitrator. The trial court was therefore required to compel arbitration and stay litigation of all issues subject to arbitration, leaving the remaining arbitrability questions for the arbitrator to decide.” No. 05-25-01444-CV (Aug. 14, 2026).