Colonel Glenn Health and Rehab, LLC; Central Arkansas Nursing Centers, Inc.; Nursing Consultants, Inc., D/B/A Professional Nursing and Rehabilitation Services; Argenta Health Services, LLC; And Michael S. Morton v. Teresa Joanne Aldrich, as Special Administrator of the Estate of Jeffrey Watton, and on Behalf of the Wrongful Death Beneficiaries of Jeffrey Watton, 599 S.W.3d 344

Resident Jeffrey Watton was admitted to Colonel Glenn Health & Rehab on May 5, 2017; admission and arbitration agreements were executed by his wife, Mary Joanne Watton, as the designated "Responsible Party."
The agreements define "Responsible Party" to include a legal guardian, an attorney-in-fact (POA), or "some other individual or family member who agrees to assist the Facility"; Mary wrote "wife" on the relationship line and did not check a box indicating POA/guardianship, and she is not Jeffrey's guardian or attorney-in-fact.
Jeffrey did not sign the arbitration agreement; the agreement waived trial by judge or jury and required binding arbitration of disputes arising from care.
Teresa Aldrich (Jeffrey’s daughter and special administrator) sued for negligence, malpractice, and statutory violations; Colonel Glenn moved to compel arbitration, asserting Mary signed in her individual capacity and that Jeffrey is bound as a third-party beneficiary.
The circuit court denied the motion to compel arbitration and declined to supply Rule 52(a)(1) findings; on appeal the Court of Appeals affirmed, holding the arbitration agreement was not enforceable against Jeffrey because Mary lacked authority to bind him and the third-party-beneficiary doctrine did not apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred by not making findings of fact and conclusions of law under Ark. R. Civ. P. 52(a)(1)	Aldrich: failure to make explicit findings not prejudicial; order denying arbitration is appealable but findings unnecessary	Colonel Glenn: Rule 52(a)(1) required because order denying motion to compel arbitration is a judgment under Rule 54(a)	Court: Rule 52(a)(1) findings not required for motions to compel arbitration; omission not reversible error
Whether Jeffrey is bound to arbitrate where his wife signed as "Responsible Party" but lacked POA/guardianship	Aldrich: Mary lacked authority to act for Jeffrey; signature was in representative, not individual, capacity; arbitration unenforceable against Jeffrey	Colonel Glenn: contractual language allowed a Responsible Party to sign in individual capacity to assist care; Jeffrey is intended third-party beneficiary and must arbitrate	Court: ambiguous whether Mary signed individually; construed against drafter; Mary lacked authority, so no valid agreement with her and third-party-beneficiary doctrine does not bind Jeffrey; denial of motion to compel affirmed

Hickory Heights Health & Rehabilitation, LLC v. Cook, 557 S.W.3d 286 (Ark. Ct. App. 2018) (arbitration agreement ambiguous where family member signed as "Responsible Party"; construed against drafter; no enforceable arbitration against resident)
Robinson Nursing & Rehabilitation Center, LLC v. Phillips, 586 S.W.3d 624 (Ark. 2019) (supreme court approving Cook and holding "Responsible Party" signature did not create enforceable arbitration against resident when signer lacked authority)
Pine Hills Health & Rehab., LLC v. Talley, 546 S.W.3d 492 (Ark. Ct. App. 2018) (refusing to bind resident where family member signed in representative capacity without authority)
Broadway Health & Rehab., LLC v. Roberts, 524 S.W.3d 407 (Ark. Ct. App. 2017) (same)
Progressive Eldercare Servs.-Chicot, Inc. v. Long, 449 S.W.3d 324 (Ark. Ct. App. 2014) (same)