James Williams v. Smyrna Residential, LLC, 685 S.W.3d 718

Granville Williams, Jr. executed a broad durable power of attorney (POA) in 2007, granting his daughter, Karen Sams, authority in "all claims and litigation matters" but not expressly for health care decisions.
In early 2020, Williams was admitted to Azalea Court, an assisted-living facility; on his behalf, Sams signed both the admission agreement and an optional arbitration agreement, which was not a condition of admission.
Williams died two months later, and his son, James Williams, brought a wrongful-death action against the facility operators, alleging negligence and other torts.
The defendants moved to compel arbitration under the signed agreement; the trial court and Court of Appeals denied the motion, finding Sams lacked authority under the POA to sign the arbitration agreement and that James Williams was not bound as a non-signatory.
The Supreme Court of Tennessee granted review to decide if Sams had authority under the POA to bind Williams to arbitration, and if James Williams (and other wrongful-death beneficiaries) were bound by the arbitration agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Was signing the arbitration agreement a "health care decision" requiring specific POA authority?	Yes; Williams' POA did not grant health care decision authority; arbitration tied to admission is a health care decision.	No; signing was a legal, not health care, decision—especially since it was optional, not a condition of admission.	Not a health care decision; signing optional arbitration unrelated to actual consent to health care.
2. Did the 2007 POA give Sams authority to sign the arbitration agreement?	No; absent specific health care powers in the POA, Sams had no authority.	Yes; POA's grant of authority over all claims/litigation includes consenting to arbitration.	POA covered all claims/litigation, thus authority existed.
3. Are wrongful-death beneficiaries bound by the arbitration agreement, despite not signing it?	No; wrongful-death action is a new, personal cause, not derivative; non-signatories can't be bound.	Yes; wrongful-death claims are derivative of decedent's claims, so beneficiaries are in privity and bound.	Yes; beneficiaries step into decedent's shoes and are bound by his contracts (including arbitration).
4. Should unique contract law/privity doctrines apply in this context?	Indirectly, argued that ordinary third-party contract rules mean beneficiaries aren’t bound.	Yes, traditional principles like privity and derivative claims mean binding effect.	Ordinary contract/privity principles apply and bind beneficiaries.

Owens v. National Health Corp., 263 S.W.3d 876 (Tenn. 2007) (addressing attorney-in-fact authority under POA for health care decisions in context of mandatory arbitration agreement at nursing home admission)
Beard v. Branson, 528 S.W.3d 487 (Tenn. 2017) (explaining nature of wrongful-death actions and who controls litigation)
Flax v. DaimlerChrysler Corp., 272 S.W.3d 521 (Tenn. 2008) (noting wrongful death actions are derivative of decedent’s rights)
Harvey ex rel. Gladden v. Cumberland Tr. & Inv. Co., 532 S.W.3d 243 (Tenn. 2017) (arbitration agreements are judged like other contracts)
Tenn. Farmers Life Reassurance Co. v. Rose, 239 S.W.3d 743 (Tenn. 2007) (interpreting POA scope by its plain terms)
Ki v. State, 78 S.W.3d 876 (Tenn. 2002) (clarifying wrongful-death suits assert decedent’s rights)
Lynn v. City of Jackson, 63 S.W.3d 332 (Tenn. 2001) (wrongful death statute does not create a new cause of action for beneficiaries)
Taylor v. Butler, 142 S.W.3d 277 (Tenn. 2004) (ordinary contract law applies to arbitration agreements)