Broemmer v. Abortion Services of Phoenix, Ltd

In Broemmer v. Abortion Services of Phoenix, Ltd., 173 Ariz. 148, 152, 840 P.2d 1013, 1017 (1992), the Arizona Supreme Court applied "reasonable expectations" to hold that an arbitration agreement was unenforceable. The plaintiff in Broemmer was an unmarried, inexperienced, high-school-educated, emotionally distressed young woman who sought counseling at an abortion clinic. Id. at 149, 152, 840 P.2d at 1014, 1017. Without providing any explanation, the clinic asked the plaintiff to sign an arbitration agreement. Id. at 150, 151, 840 P.2d at 1015, 1016. She did so even though years later she "was still not sure 'what arbitration is.'" Id. at 152, 840 P.2d at 1017.