Dueñas v. Life Care Centers of America, Inc.
236 Ariz. 130
| Ariz. Ct. App. | 2014Background
- Aspeitia was admitted to Glendale Care Center for respite care on four occasions in 2011.
- After Aspeitia’s death in 2012, her daughter Dueñas, as special administrator, sued for wrongful death and APSA violations on behalf of the estate and statutory beneficiaries.
- Defendants moved to dismiss, arguing the claims were subject to arbitration agreements signed by Dueñas on Aspeitia’s behalf.
- Dueñas argued the arbitration agreements were unenforceable and did not bind the statutory beneficiaries or apply to care during last two admissions for which she did not sign.
- The superior court granted dismissal, and the court of appeals granted relief on appeal, reversing in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a decedent’s arbitration bind statutory heirs to arbitrate wrongful-death claims? | Dueñas: heirs are not bound by decedent’s arbitration | Glendale: heirs fall within agreement via 'heirs' worded language | No; beneficiaries may pursue wrongful-death claims in court |
| Who decides existence and scope of arbitration when multiple transactions occur? | Dueñas: court should determine existence/scope from content of agreements | Glendale: arbitrator decides scope for disputes within agreed terms | Existence of agreement generally decided by court; scope may be delegated to arbitrator; in this case scope limited |
| Are APSA claims arising from Aspeitia’s last two admissions arbitrable? | Dueñas: APSA claims from last two admissions should be in court | Glendale: APSA claims are arbitrable if covered by agreement | APSA claims from last two admissions not arbitrable; APSA claims arising from first two stays dismissed without prejudice |
Key Cases Cited
- Estate of DeCamacho v. La Solana Care & Rehab, Inc., 234 Ariz. 18 (App. 2014) (arbitration scope and third-party claims analysis)
- Huebner v. Deuchle, 109 Ariz. 549 (1973) (wrongful-death beneficiary claims belong to beneficiaries)
- Broemmer v. Abortion Services of Phoenix, Ltd., 173 Ariz. 148 (1992) (reasonable expectations; contracting with vulnerable individuals)
- Clark v. Renaissance West, L.L.C., 232 Ariz. 510 (App. 2013) (procedural unconscionability factors; costs and hardship)
- Smith v. Pinnamaneni, 227 Ariz. 170 (App. 2011) (non-parties bound to arbitration by contract features)