In In re Kellogg Brown & Root, Inc., 166 S.W.3d 732, 739 (Tex. 2005), a signatory to a fabrication contract containing an arbitration clause sought to compel Kellogg, Brown & Root (KBR) to arbitrate its quantum meruit claim against that party, on the grounds that KBR's claims for "labor and services were linked inextricably" to the fabrication contract. Id. at 740.
Because KBR provided its labor and services pursuant to a different contract and sought its benefits from that contract, and thus sought no benefit from the fabrication contract, the supreme court rejected the claimant's reliance on the doctrine of direct-benefit estoppel in seeking to compel KBR to arbitrate its claim. Id. at 741.