Bristow v. Jameson
In Bristow v. Jameson, No. 01-96-00113-CV, 1996 WL 277138 (Tex. App.--Houston [1st Dist.] May 14, 1996, no pet.), the parties had a prior representation contract that did not contain an arbitration provision.
During the course of the suit in Bristow, the parties entered into a second representation contract, which did contain an arbitration provision.
The arbitration provision in the second contract stated, "Any disputes relating to this Contract or arising in connection with Attorney's representation of Client will be subject to binding arbitration . . . ."
The First Court of Appeals concluded that the trial court correctly determined that the arbitration provision in the second contract applied only to matters relating to that contract, not to matters relating to the first contract. Id.