Progressive Eldercare Services-Columbia, Inc. v. Patricia Griffin, as Special Administrator of the Estate of Dossie Lee Williams, and on Behalf of the Wrongful Death Beneficiaries of Dossie Lee Williams

2023 Ark. App. 121, 662 S.W.3d 237
CourtCourt of Appeals of Arkansas
DecidedMarch 1, 2023
StatusPublished
Cited by1 cases

This text of 2023 Ark. App. 121 (Progressive Eldercare Services-Columbia, Inc. v. Patricia Griffin, as Special Administrator of the Estate of Dossie Lee Williams, and on Behalf of the Wrongful Death Beneficiaries of Dossie Lee Williams) 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
Progressive Eldercare Services-Columbia, Inc. v. Patricia Griffin, as Special Administrator of the Estate of Dossie Lee Williams, and on Behalf of the Wrongful Death Beneficiaries of Dossie Lee Williams, 2023 Ark. App. 121, 662 S.W.3d 237 (Ark. Ct. App. 2023).

Opinion

Cite as 2023 Ark. App. 121 ARKANSAS COURT OF APPEALS DIVISION I No. CV-22-121

PROGRESSIVE ELDERCARE SERVICES-COLUMBIA, INC., D/B/A Opinion Delivered March 1, 2023 THE GREEN HOUSE COTTAGES OF WENTWORTH PLACE; APPEAL FROM THE COLUMBIA WENTWORTH, LLC, D/B/A THE COUNTY CIRCUIT COURT GREEN HOUSE COTTAGES OF [NO. 14CV-19-282] WENTWORTH PLACE; T. MARQUEL (KELLY) PARK, ADMINISTRATOR OF HONORABLE SPENCER G. SINGLETON, THE GREEN HOUSE COTTAGES OF JUDGE WENTWORTH PLACE; JOHN DOE I; JOHN DOE II; JOHN DOE III; JOHN DOE IV; AND JOHN DOE V AFFIRMED APPELLANTS

V.

PATRICIA GRIFFIN, AS SPECIAL ADMINISTRATOR OF THE ESTATE OF DOSSIE LEE WILLIAMS, DECEASED, AND ON BEHALF OF THE WRONGFUL DEATH BENEFICIARIES OF DOSSIE LEE WILLIAMS, DECEASED APPELLEE

KENNETH S. HIXSON, Judge

Appellants Progressive Eldercare Services-Columbia, Inc., d/b/a The Green House

Cottages of Wentworth Place and numerous other associated parties (collectively

“Progressive”) bring this interlocutory appeal from an order denying their motion to compel arbitration of a complaint filed by appellee Patricia Griffin, as special administrator of the

estate of Dossie Lee Williams, deceased, and on behalf of the wrongful-death beneficiaries

of Dossie Lee Williams, deceased. Progressive argues that the trial court erred in refusing to

enforce a valid arbitration agreement. For the following reasons, we affirm the trial court’s

order denying Progressive’s motion to compel arbitration.

On September 26, 2016, Dossie Lee Williams was admitted to The Green House

Cottages of Wentworth Place for medical, nursing, and personal care. Dossie Lee Williams

did not sign any of the admission documents; instead, her daughter Pamela Green 1 signed

the documents necessary for Dossie’s admission. Among the documents signed by Pamela

was an admission agreement, which stated:

The undersigned resident or resident’s representative (collectively, the “Resident”) hereby requests admission of /s/ Dossie Williams [Name of Resident] to Green House Cottages of Wentworth Place (The “Nursing Facility” or “Facility”) for medical, nursing, and personal care. The Nursing Facility and the Resident agree to the following terms for the Resident’s care.

The admission agreement required Dossie to appoint a family member to act as the

“Responsible Party” in admission, care and treatment, and discharge decisions. Pamela was

listed as the responsible party. The admission agreement also asked two questions: “Do you

have a power of attorney?” and “Do you have a legal guardian?” Both questions were

answered no. Dossie did not sign the admission agreement, but Pamela signed as the

“Resident’s Representative.”

1 Pamela Green is appellee Patricia Griffin’s sister.

2 That same day, Pamela also signed an arbitration agreement that was incorporated by

the admission agreement. The arbitration agreement was required to be signed as a

condition of admission to the nursing home.2 The arbitration agreement stated that “any

claim, dispute, or controversy (“claim”) between the parties shall be resolved by final and

binding arbitration.” The arbitration agreement contained a box next to the signature line

asking for the identity of the signatory; the options on the list of signatories were “Resident,”

“Guardian,” “Power of Attorney,” “Spouse,” and “Adult Children.” Pamela checked the

box for “Adult Children.” A separate line below the signature block 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. Pamela signed the arbitration agreement as the “Responsible Party.”

Dossie was a resident of the nursing home from September 26, 2016, through March

6, 2018, and she passed away on March 11, 2018. Patricia Griffin was thereafter appointed

special administrator of Dossie’s estate. Patricia filed a complaint against Progressive alleging

multiple causes of action, including negligence, medical negligence, and violations of the

Arkansas Long-Term Care Residents’ Rights statute. Progressive filed an answer denying all

liability and reserving the right to enforce the arbitration agreement.

2 The agreement contained a ten-day right of rescission, which included language stating that the resident would not be discharged from the facility if the resident exercised his or her right to rescission.

3 Progressive subsequently filed a motion to compel arbitration, contending that the

arbitration agreement encompassed the claims in Patricia’s complaint. Progressive argued

that there was a valid contract between Progressive and Pamela (who had signed both the

admission agreement and the arbitration agreement) and that Dossie was a third-party

beneficiary to the contract. Progressive also cited the supreme court’s decision in Jorja

Trading, Inc. v. Willis, 2020 Ark. 133, 598 S.W.3d 1, and argued that the Federal Arbitration

Act (“FAA”)3 preempts our line of third-party-beneficiary arbitration cases because those

cases employ arbitration-specific rules with respect to third-party beneficiaries rather than

general contract law. Patricia filed a response denying the enforceability of the arbitration

agreement and asserting that Pamela lacked the authority to execute the agreement on

Dossie’s behalf.

The trial court held a hearing on Progressive’s motion to compel arbitration. After

hearing arguments of counsel, the trial court denied the motion. In so doing, the trial court

stated that the motion herein presented the same issues that the trial court had recently

rejected in Courtyard Rehabilitation & Health Center, LLC v. Estate of Tice.4

3 9 U.S.C. §§ 1–16. 4 At the time of the hearing below and the entry of the trial court’s order denying arbitration, Tice was pending before our court on appeal. We have since affirmed that case, holding that the trial court did not err in denying the motion to compel arbitration. Courtyard Rehab. & Health Ctr., LLC v. Estate of Tice, 2022 Ark. App. 327. The trial court herein was correct in stating that Tice and the instant case involve the same issues.

4 In this appeal, Progressive challenges the trial court’s order denying the motion to

compel arbitration. Progressive argues that there was a valid agreement to arbitrate that

encompasses the parties’ dispute; that Dossie was bound to the arbitration agreement under

the third-party-beneficiary doctrine; and that the trial court erred in applying an arbitration-

specific rule to the third-party-beneficiary doctrine.

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

to Arkansas Rule of Appellate Procedure–Civil 2(a)(12) (2002). We review a trial court’s

denial of a motion to compel arbitration de novo on the record. Robinson Nursing & Rehab.

Ctr., LLC v. Phillips, 2019 Ark. 305, 586 S.W.3d 624. While we are not bound by the trial

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

the law, we will accept its decision as correct on appeal. Progressive Eldercare Servs.-Morrilton,

Inc. v. Taylor, 2021 Ark. App. 379.

The FAA governs the agreements at issue. The FAA establishes a national policy

favoring arbitration when the parties contract for that mode of dispute resolution. Reg’l Care

of Jacksonville, LLC v. Henry, 2014 Ark. 361, 444 S.W.3d 356. Likewise, in Arkansas,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ark. App. 121, 662 S.W.3d 237, Counsel Stack Legal Research, https://law.counselstack.com/opinion/progressive-eldercare-services-columbia-inc-v-patricia-griffin-as-arkctapp-2023.