Williams v. Smyrna Residential, LLC
Annotate this Case
In a wrongful death action against an assisted-living facility, the Supreme Court of Tennessee held that the claims were subject to arbitration as per an agreement signed by the deceased's attorney-in-fact. The court clarified two key points. First, signing an optional arbitration agreement is not a "health care decision" under the Durable Power of Attorney for Health Care Act. Second, the attorney-in-fact had the authority to sign the arbitration agreement on the deceased's behalf, considering the durable power of attorney gave her the power to act for him in "all claims and litigation matters". The court further ruled that the deceased's son, who brought the wrongful death action, was bound by the arbitration agreement because his claims were derivative of his father's. Consequently, the court reversed the decision of the Court of Appeals and remanded the case to the trial court.
In the case, Granville Williams, Jr. died while residing at an assisted-living facility run by Smyrna Residential, LLC. His son James Williams filed a wrongful death action against the facility. The decedent's daughter, acting as his attorney-in-fact under a power of attorney, had signed an arbitration agreement with the facility at the time of his admission. The arbitration agreement was not a condition of admission to the facility. The key issues were whether the attorney-in-fact had the authority to sign the arbitration agreement and whether the son, who was not a party to the agreement, was nevertheless bound by it.
Court Description: Authoring Judge: Justice Sarah K. Campbell
Trial Court Judge: Judge Bonita J. Atwood
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.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.