BARRY ROWLAND; DONNA ROWLAND, Plaintiffs - Appellees, v. SANDY MORRIS FINANCIAL & ESTATE PLANNING SERVICES, LLC; SANDEVA O'BRYAN MORRIS, Defendants - Appellants, and GLOBAL FINANCIAL PRIVATE CAPITAL, LLC; GF INVESTMENT SERVICES, LLC; MINNESOTA LIFE INSURANCE COMPANY, Defendants., 993 F.3d 253

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HOLDINGS: [1]-The district court was the proper one to resolve the parties' dispute over whether they agreed to arbitrate, because 9 U.S.C.S. § 4 made clear that it was up to courts to determine whether a contract has been formed; [2]-Based on the undisputed evidence submitted by both parties, there was no meeting of the minds—and thus no contract—because both parties did not agree to the same terms; unilateral unratified material changes on the part of a financial advisor and her firm prevented the formation of a contract.