The U.S. Court of Appeals for the Sixth Circuit addressed fundamental questions about digital contract formation in *Dahdah v. Rocket Mortgage, LLC*, a case that explores when online actions constitute valid offers and acceptances in the modern internet economy.
The court's opinion, issued Jan. 26, 2026, and recommended for publication, indicates its potential significance as precedent for future disputes involving online contract formation. The case arose from the U.S. District Court for the Eastern District of Michigan at Flint, where District Judge F. Kay Behm presided over the original proceedings.
According to the opinion authored by Circuit Judge Murphy, the case centers on determining "what actions qualify as valid 'offers' and 'acceptances' to form contracts in the online world." The court noted that websites frequently inform consumers they will "agree to" or "accept" various contractual terms, including arbitration provisions, by engaging in specific conduct such as clicking buttons or registering accounts.
The legal dispute involves Michael Dahdah as the plaintiff-appellee and Rocket Mortgage, LLC, as the defendant-appellant. Rocket Mortgage appealed from the district court's decision, with oral arguments held April 30, 2025, before Circuit Judges Gibbons, White, and Murphy.
Representing Rocket Mortgage, attorney William M. Jay of Goodwin Procter LLP argued the company's position, supported by colleagues W. Kyle Tayman, Benjamin Hayes, and Brooks R. Brown. James S. Wertheim of The HQ Firm, P.C., represented Dahdah in the appellate proceedings.
The case highlights the evolving nature of contract law in the digital age, where traditional principles of offer and acceptance must be applied to new technological contexts. Courts increasingly face questions about when a consumer's online behavior constitutes legally binding agreement to terms and conditions, particularly regarding arbitration clauses that can significantly impact a consumer's legal rights.
The Sixth Circuit's decision to recommend the opinion for publication under Circuit Rule 32.1(b) signals the court's view that the ruling addresses important legal principles with broader application beyond the specific parties involved. Published opinions carry precedential weight and guide future court decisions within the circuit's jurisdiction, which covers Michigan, Ohio, Kentucky, and Tennessee.
For Rocket Mortgage, one of the nation's largest mortgage lenders, the appellate ruling represents a significant development in how courts will evaluate the company's online contract formation practices. The company frequently engages with consumers through digital platforms where terms of service and arbitration agreements are presented alongside loan applications and account registration processes.
The case reflects broader trends in consumer protection law, where courts must balance the efficiency and convenience of online commerce with ensuring that consumers genuinely understand and agree to the legal obligations they undertake through digital interactions. Questions often arise about whether terms are sufficiently prominent, whether the mechanism for acceptance is clear, and whether consumers have meaningful opportunity to review contractual provisions before agreeing.
Digital contract formation disputes have become increasingly common as more financial services move online. Courts have developed various frameworks for evaluating online agreements, distinguishing between "clickwrap" agreements where users must affirmatively click to agree, "browsewrap" agreements where continued use of a website constitutes acceptance, and hybrid approaches that combine different elements.
The timing of the Sixth Circuit's decision, coming nearly two years after the district court proceedings began in 2022, reflects the complexity of the legal issues involved and the court's careful consideration of the competing arguments. The extended timeline from oral arguments in April 2025 to the January 2026 decision suggests thorough deliberation by the three-judge panel.
For consumers engaging with online financial services, the ruling will likely influence how companies structure their digital interfaces and present contractual terms. The decision may impact how prominently arbitration clauses must be displayed and what specific actions constitute valid acceptance of such provisions.
The case also demonstrates the continued relevance of fundamental contract principles in the digital economy. While the medium of contract formation has evolved dramatically with internet technology, courts must still apply traditional doctrines of mutual assent, consideration, and enforceability to determine when legally binding agreements exist.
As online lending and financial services continue to expand, the Sixth Circuit's analysis in *Dahdah v. Rocket Mortgage* will likely serve as important guidance for both companies designing digital platforms and consumers navigating online financial transactions. The published opinion adds to the growing body of precedent addressing how contract law adapts to technological innovation while preserving essential consumer protections.
