Marcus & Millichap Real Estate Investment Services of Seattle, Inc., Appellant, v. Yates, Wood & MacDonald, Inc., Respondent., 192 Wn. App. 465

Summary

HOLDINGS: [1]-Notwithstanding the enactment of the Uniform Arbitration Act, Wash. Rev. Code ch. 7.04A, the preexisting rule that voluntary membership in a professional organization gives rise to a corresponding obligation to comply with that organization's bylaws, including an agreement to arbitrate, retains its viability; [2]-A binding agreement to arbitrate was adequately evidenced by proof of membership in the Commercial Brokers Association--a signed membership application form was not required to form a valid agreement to arbitrate under the Association's bylaws; [3]-A summary judgment standard applied to the determination of the enforceability of the agreement; [4]-The evidence showed that the brokerage was a member of the Association and, as such, it was subject to the arbitration agreement in the Association's bylaws.