James Williams v. Smyrna Residential, LLC
This appeal addresses the enforceability of an arbitration agreement in a wrongful death lawsuit. James Williams sued Smyrna Residential, LLC and Americare Systems, Inc., alleging their negligence led to his father's death in an assisted living facility. Defendants sought to compel arbitration based on an agreement signed by the decedent's daughter, Karen Sams, who held a durable power of attorney. The Trial Court denied the motion, finding Sams lacked authority as her POA did not cover healthcare decisions, and the wrongful death beneficiaries were not bound. The Court of Appeals affirmed, holding that executing the arbitration agreement was a healthcare decision, which Sams' general POA did not authorize. Furthermore, the court clarified that wrongful death beneficiaries bring their own right of action and are not bound by agreements to which they were not parties.