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Clara Manley v. Humboldt Nursing Home, Inc.

Tenn. Ct. App.September 18, 2020No. W2019-00131-COA-R3-CV
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Case Details

Judge(s)
Judge W. Neal McBrayer
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The appellate court affirmed the trial court's denial of the nursing home's motion to compel arbitration, finding that the nursing home failed to establish a valid arbitration agreement because the daughter lacked authority to sign the arbitration agreement on behalf of her deceased mother.

Excerpt

After a nursing home resident died, her daughter filed a wrongful death action against the facility. The nursing home moved to compel arbitration based on an arbitration agreement signed by the daughter when her mother was admitted to the facility. The daughter claimed that she lacked authority to sign the arbitration agreement for her mother. The trial court agreed and denied the motion to compel. On appeal, we conclude that the Federal Arbitration Act required the trial court to resolve the issue of whether an agreement to arbitrate had been formed. Because the nursing home failed to establish an agreement to arbitrate had been formed with the patient, we affirm.

What This Ruling Means

**What Happened:** When Clara Manley's mother died at Humboldt Nursing Home, Manley sued the facility for wrongful death. The nursing home tried to force the case into private arbitration instead of court, pointing to an arbitration agreement that Manley had signed when her mother was admitted to the facility. Manley argued that she didn't have the legal authority to sign away her mother's right to go to court. **What the Court Decided:** Both the trial court and appeals court sided with Manley. The courts ruled that the nursing home couldn't force arbitration because Manley lacked the proper authority to sign the arbitration agreement on her mother's behalf. This meant the wrongful death lawsuit could proceed in regular court rather than private arbitration. **Why This Matters for Workers:** This ruling protects families from being forced into arbitration when they don't have proper legal authority to agree to it. Many healthcare facilities and employers try to use arbitration clauses to avoid jury trials, but this case shows that courts will scrutinize whether these agreements are valid. It reinforces that you can't be bound by arbitration agreements that weren't properly authorized.

This summary was generated to explain the ruling in plain English and is not legal advice.

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