Hickory Heights Health & Rehab, LLC v. Wesley Smith, as Special Administrator of the Estate of Bettye Jean Smith

2022 Ark. App. 190
CourtCourt of Appeals of Arkansas
DecidedApril 27, 2022
StatusPublished
Cited by1 cases

This text of 2022 Ark. App. 190 (Hickory Heights Health & Rehab, LLC v. Wesley Smith, as Special Administrator of the Estate of Bettye Jean Smith) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hickory Heights Health & Rehab, LLC v. Wesley Smith, as Special Administrator of the Estate of Bettye Jean Smith, 2022 Ark. App. 190 (Ark. Ct. App. 2022).

Opinion

Cite as 2022 Ark. App. 190 ARKANSAS COURT OF APPEALS DIVISION II No. CV-21-392

Opinion Delivered April 27, 2022

HICKORY HEIGHTS HEALTH AND REHAB, LLC; CENTRAL ARKANSAS NURSING CENTERS, INC.; HICKORY MANOR, LLC; AND MICHAEL S. APPEAL FROM THE PULASKI MORTON COUNTY CIRCUIT COURT, ELEVENTH DIVISION [NO. 60CV-20-2846] APPELLANTS

V.

WESLEY SMITH, AS SPECIAL ADMINISTRATOR OF THE ESTATE HONORABLE PATRICIA JAMES, OF BETTYE JEAN SMITH, DECEASED, JUDGE AND ON BEHALF OF THE WRONGFUL DEATH BENEFICIARIES OF BETTYE JEAN SMITH APPELLEE AFFIRMED

WAYMOND M. BROWN, Judge

Appellants Hickory Heights Health and Rehab, LLC; Central Arkansas Nursing

Centers, Inc.; Hickory Manor, LLC; and Michael S. Morton bring this interlocutory appeal

of an order of the Pulaski County Circuit Court denying their motion to compel arbitration

of a negligence complaint filed by appellee Wesley Smith as special administrator of the estate of Bettye Jean Smith. Appellants argue that the circuit court erred in failing to enforce

a valid arbitration agreement. We find no error and affirm.

On February 19, 2018, Wesley assisted with Bettye’s admission to Hickory Heights

Health and Rehab, LLC (Hickory Heights), for medical, nursing, and personal care.1 The

facility required signatures on necessary documents. Wesley signed the admission form for

his mother as the responsible party.2 However, Bettye’s name was not anywhere on the

admission agreement. That same day, Wesley also signed an arbitration agreement that was

required as a condition of Bettye’s admission to the facility. Wesley signed the arbitration

agreement as the responsible party and indicated that his relationship to Bettye was “son.”

Bettye’s name was printed on the resident line in the arbitration agreement in what appeared

to be the handwriting of the facility’s representative. A separate line below the signatures

read as follows: “_______ (Check if applicable): A copy of my guardianship papers, durable

power of attorney or other documentation has been provided to the Facility and is attached.”

The blank was not checked.

1 Wesley had been appointed medical power of attorney (POA) by Bettye in December 2005. 2 Responsible party was defined in the admission agreement as “the Resident’s legal guardian, if one has been appointed, the Resident’s attorney-in-fact, if the Resident executed a power of attorney, or some other individual or family member who agrees to assist the Facility in providing for the Resident’s health, care and maintenance.” The definition also included someone who “manages, uses, controls, or otherwise has legal access to Resident’s income or resources that legally may be used to pay Resident’s share of cost or other charges not paid by the Arkansans Medicaid Program or any other source.”

2 Bettye was a resident at Hickory Heights from February 19, 2018, until October 11,

2019. Bettye died on November 9, 2019. Wesley was appointed special administrator of

Bettye’s estate on December 31. He filed the negligence complaint against appellants on

May 5, 2020. He stated that as result of appellants’ negligence, Bettye suffered numerous

physical and emotional injuries: falls, medication errors, right scapula fracture, pelvic ring

fracture, severe pain and suffering, and death. He contended that Bettye’s injuries led to

degradation, mental anguish, distress, unnecessary hospitalizations and treatment, and

emotional trauma and eventually caused her death. Appellants filed an answer on June 3

asserting the existence of an arbitration agreement and denying the material allegations of

Wesley’s complaint.

Appellants filed a motion to compel arbitration on August 21. They contended that

Wesley executed the arbitration agreement when Bettye was admitted to Hickory Heights,

and at the time the agreements were signed, Wesley had authority under a medical POA

executed by Bettye on December 28, 2005. Appellants maintained that by signing the

agreements, Wesley bound Bettye and her estate to the terms of the arbitration agreement.

Appellants attached a copy of the medical POA to their motion to compel arbitration. The

authority granted in the medical POA was to “kick in” if it was determined that Bettye was

incapacitated to provide informed consent for medical treatment and surgical and diagnostic

procedures. The document permitted Wesley to “make health care decisions and to provide,

withhold, or withdraw consent on [Bettye’s] behalf for medical treatment and surgical and

diagnostic procedures, to apply for public benefits to defray the costs of health care, and to

3 authorize [Bettye’s] admission to or transfer from a health care facility.” Wesley filed a

response on September 1 contending that he signed the necessary documents as Bettye’s son

and not under any legal authority to bind Bettye, who he noted was not identified in the

admission agreement. He stated that the line outlining his legal authority was left blank on

the arbitration agreement because he did not hold legal authority to bind Bettye to the

agreement. Wesley also said that the medical POA executed in his favor did not include the

power to waive Bettye’s right to a jury trial for personal-injury claims.3 Appellants filed a

reply on September 14, contending that Wesley signed the documents as Bettye’s attorney-

in-fact and that the lack of a checkmark does not destroy the authority Wesley had. They

also argued that Wesley had the authority to consent to the arbitration agreement on Bettye’s

behalf because the arbitration agreement was in connection with Bettye’s admission to

Hickory Heights. Wesley filed a supplemental response on September 22, again contending

that his authority under the medical POA was limited to health-care decisions and was not

adequate to bind Bettye or her estate to arbitration.

The circuit court held a hearing on appellants’ motion to compel on March 16, 2021.

Appellants maintained that the arbitration agreement was incorporated into the admission

agreement, which fell under the authority granted to Wesley in the medical POA. Wesley

argued that the medical POA did not give him the authority to bind Bettye to arbitration.

3 Appellants also made other contentions; however, they are not relevant to the issue on appeal.

4 The circuit court did not make an oral ruling but informed the parties that it wished to go

over all the evidence and exhibits before deciding. The circuit court filed an order on April

23 denying appellants’ motion to compel arbitration upon a finding that “the power of

attorney at issue in this matter did not give [Wesley] the right to bind his Mother to

arbitration.” Appellants filed a timely notice of appeal on May 21.

An order denying a motion to compel arbitration is immediately appealable pursuant

to Arkansas Rule of Appellate Procedure–Civil 2(a)(12).4 We review a circuit court’s denial

of a motion to compel arbitration de novo on the record. 5 While we are not bound by the

circuit court’s decision, in the absence of a showing that the circuit court erred in its

interpretation of the law, we will accept its decision as correct on appeal.6

Generally, the terms of an arbitration contract do not apply to those who are not

parties to the contract.7 In Arkansas, the presumption is that the parties contract only for

themselves; thus, a contract will not be construed as having been made for the benefit of a

third party unless it clearly appears that such was the intention of the parties.

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2022 Ark. App. 190, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hickory-heights-health-rehab-llc-v-wesley-smith-as-special-arkctapp-2022.