James Williams v. Smyrna Residential, LLC

Citation:

Court: Tennessee Supreme Court · Filed: 2024-02-16 · Docket: M2021-00927-SC-R11-CV
Published
Impact Score: 0/100 — Low impact: This case is narrowly focused with minimal precedential value.

Case Overview

James Williams v. Smyrna Residential, LLC is a court opinion from the Tennessee Supreme Court, filed on 2024-02-16 (Docket No. M2021-00927-SC-R11-CV).

Precedential Status: Published. This opinion may be cited as authority in future cases.

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Court Syllabus

Granville Williams, Jr., died while residing at an assisted-living facility. The central question in this appeal is whether his son's ensuing wrongful-death action against the facility must be arbitrated. To answer that question, we must resolve two subsidiary issues—first, whether the attorney-in-fact who signed the arbitration agreement as Williams's representative had authority to do so and, second, whether Williams's son and other wrongful-death beneficiaries who were not parties to the arbitration agreement nevertheless are bound by it. We hold that signing an optional arbitration agreement—that is, one that is not a condition of admission to a health care facility—is not a "health care decision" within the meaning of the Durable Power of Attorney for Health Care Act. The durable power of attorney that gave Williams's attorney-in-fact authority to act for him in "all claims and litigation matters" thus provided authority to enter the optional arbitration agreement even though it did not specifically grant authority to make health care decisions. We further hold that Williams's son is bound by the arbitration agreement because his wrongful-death claims are derivative of his father's claims. Because we conclude that the claims in this action are subject to arbitration, we reverse the Court of Appeals' contrary decision and remand to the trial court.

Case Details

Case NameJames Williams v. Smyrna Residential, LLC
Citation
CourtTennessee Supreme Court
Date Filed2024-02-16
Docket NumberM2021-00927-SC-R11-CV
Precedential StatusPublished
Impact Score0 / 100
Jurisdictiontn

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