Miller v. Life Care Centers of America, Inc.Annotate this Case
The Supreme Court reversed the judgment of the district court granting Defendant's motion to compel arbitration under the "voluntary agreement for arbitration" Rick Miller signed on behalf of his mother, Julia Miller, after she was admitted to Life Care Center of Casper (LCCC), holding that Rick lacked authority to execute the agreement.
After Julia died allegedly from injuries sustained during a series of mishaps at LCCC Rick filed this complaint stating claims of negligence and premises liability against Defendant. Defendant filed a motion to compel arbitration. The court granted the motion. The Supreme Court reversed, holding (1) Julia's durable power of attorney for health care did not grant Rick express actual authority to sign the arbitration agreement; (2) Julia did not hold Rick out as having apparent authority to sign the agreement; and (3) Rick was not authorized to execute the arbitration agreement as Julia's "surrogate" under the Wyoming Health Care Decisions Act, Wyo. Stat. Ann. 35-22-401 through 416.