We disagree. ΒΆ10 This is not a case like Union Machinery Supply Co. v. Taylor-Morrison Logging Co., 143 Wash. 154, 254 P. 1094 (1927), relied on by Grover. In Union Machinery, the officers of a logging company had signed a promissory note in their official capacities.
As such, the parties bound to arbitrate by the Quiggs' signatures on these agreements are the Quiggs' corporate principals, not the Quiggs individually. Union Mach. & Supply Co. v. Taylor-Morrison Logging Co., 143 Wash. 154,157-62, 254 P.2d 1094 (1927) (collecting cases). However, the federal courts have held that, under "'common law principles of contract and agency law,'" a nonsignatory may consent to arbitrate a dispute "under ... five distinct theories."