Courtyard Gardens Health & Rehabilitation, LLC v. Quarles

Summary

The Arkansas Supreme Court affirmed the denial of a nursing-facility defendants’ motion to compel arbitration. The court held that the resident’s son lacked actual or statutory authority to bind her to the arbitration agreement, and therefore no valid arbitration agreement existed as a matter of law. The court did not reach the remaining enforceability, waiver, assent, or cross-appeal issues.

Holdings

1. Ronald Quarles lacked actual authority to bind the decedent because the evidence did not establish that the decedent authorized him to sign the second arbitration agreement on her behalf.
2. Section 20-9-602(11) did not authorize an adult child to sign an arbitration agreement on behalf of a parent of unsound mind.
3. There was no valid arbitration agreement as a matter of law.
4. The court did not consider Courtyard Gardens’ third-party-beneficiary argument because Courtyard Gardens failed to obtain a specific ruling on that issue in the circuit court.

Questions Presented

1. Whether Ronald Quarles had actual authority to bind the decedent to the arbitration agreement.
2. Whether Arkansas Code Annotated section 20-9-602(11) gave Ronald statutory authority to bind the decedent to the arbitration agreement.
3. Whether a valid arbitration agreement existed as a matter of law.
4. Whether the remaining enforceability, waiver, assent, and cross-appeal issues were moot after the court determined that no valid arbitration agreement existed.

Disposition

affirmed