Juan Mendez, Jr., etc. v. Hampton Court Nursing Center, LLC., 203 So. 3d 146

Background

Hampton Court admitted Juan Mendez Sr. in 2009; his son, Juan Mendez Jr., signed an admission contract (including an arbitration clause) on a line labeled "Resident’s Representative." The father did not sign.
While under care, the father suffered an eye infection that led to removal of an eye; the son later sued on the father’s behalf for negligence and statutory violations.
Hampton Court moved to compel arbitration under the admission contract; the trial court granted the motion.
The Third District affirmed, concluding the father was an intended third-party beneficiary and therefore bound by the arbitration clause.
The Florida Supreme Court granted review to resolve conflict among districts about whether a nursing-home resident who did not sign (or agree to) the contract can be bound by its arbitration clause.
The Supreme Court quashed the Third District, holding the third-party beneficiary doctrine does not bind the nonconsenting resident to arbitration and remanded for further proceedings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a nursing-home resident who did not sign or agree to an admission contract can be compelled to arbitrate under that contract	Mendez: The resident is not bound because he never agreed to the contract or arbitration clause	Hampton Court: The resident is an intended third-party beneficiary of the son’s admission contract and thus bound by arbitration	The Court: Third-party beneficiary doctrine does not bind a nonconsenting resident to arbitration; quashes Third District decision
Whether third-party beneficiary law allows contracting parties to bind a nonparty to arbitration	Mendez: Third-party beneficiary doctrine should not be used to impose burdens on a nonparty who never agreed	Hampton Court: Third-party beneficiary status permits enforcement of contract terms (including arbitration) against the beneficiary	The Court: Third-party beneficiary doctrine permits nonparties to enforce contract benefits but does not allow two parties to bind a nonparty without that party’s assent
Whether agency or the son’s signature as "representative" binds the resident	Mendez: Record does not establish agency; Hampton Court disclaimed reliance on agency	Hampton Court: Son signed as "Resident’s Representative," so resident should be bound	The Court: Agency existence is a fact question but Hampton Court disclaimed agency reliance; resolution not necessary to decision
Whether the father's mental incapacity or absence of guardian justifies binding him to contract terms	Mendez: Mental capacity irrelevant to third-party beneficiary analysis; guardianship procedures exist if contracting for incapacitated persons	Hampton Court: Resident’s incapacity does not prevent third-party beneficiary enforcement	The Court: Incapacity does not change analysis; Legislature’s guardianship scheme exists and the nursing home could have sought appointment rather than rely on common-law principles

Key Cases Cited

Mendez v. Hampton Court Nursing Ctr., LLC, 140 So.3d 671 (Fla. 3d DCA 2014) (district-court decision holding resident bound as intended third-party beneficiary)
Alterra Healthcare Corp. v. Estate of Linton ex rel. Graham, 953 So.2d 574 (Fla. 1st DCA 2007) (first-district decision treating resident as intended third-party beneficiary)
Perry ex rel. Perry v. Sovereign Healthcare Metro W., LLC, 100 So.3d 146 (Fla. 5th DCA 2012) (fifth-district decision applying agency/authority analysis and declining to bind nonsignatory resident)
Fletcher v. Huntington Place Ltd. P’ship, 952 So.2d 1225 (Fla. 5th DCA 2007) (fifth-district decision refusing to bind resident where signer acted only as guarantor)
Lepisto v. Senior Lifestyle Newport Ltd. P’ship, 78 So.3d 89 (Fla. 4th DCA 2012) (fourth-district decision analyzing authority of signer and declining to bind resident)
In re Estate of McKibbin, 977 So.2d 612 (Fla. 2d DCA 2008) (second-district decision relying on factual absence of incapacity or agency)
Found. Health v. Westside EKG Assocs., 944 So.2d 188 (Fla. 2006) (Florida Supreme Court articulation of elements for third-party-beneficiary enforcement)
Nat'l Gypsum Co. v. Travelers Indem. Co., 417 So.2d 254 (Fla. 1982) (requiring third-party beneficiaries to comply with contract conditions to obtain contractual remedies)
Arthur Andersen LLP v. Carlisle, 556 U.S. 624 (U.S. 2009) (recognizing traditional state-law principles that can bind nonparties to contracts)