Progressive Eldercare Services - Morrilton, Inc., D/B/A/ Brookridge Cove Rehabilitation and Care Center; Progressive Eldercare Services, Inc.; Jej Investments, LLC; Ponthie Holdings, LLC; Procare Therapy Services, LLC; Southern Administrative Services, LLC; Professional Nursing Solutions, LLC; Careplus Staffing Services, LLC; Ross Ponthie; John Ponthie; And Bobbi Helton, in Her Capacity as Administrator of Brookridge Cove Rehabilitation and Care Center v. Nancy Taylor, as Special Administrator of the Estate of Virginia Rankin, and on Behalf of the Wrongful Death Beneficiaries of Virginia Rankin, 2021 Ark. App. 379

On Feb 23, 2018, Nancy Taylor signed nursing-home admission documents and an attached arbitration agreement on behalf of her mother, Virginia Rankin, as part of admission to Brookridge Cove; Taylor checked "adult children" and did not indicate a power of attorney.
The arbitration agreement was a condition of admission and included a 10‑day rescission right.
On Feb 27, 2018, four days later, Rankin executed a durable health‑care power of attorney appointing Taylor as her attorney‑in‑fact.
Rankin resided at the facility until her death in Sept. 2018; Taylor was later appointed special administrator and sued for wrongful death in July 2019.
Progressive moved to compel arbitration, arguing Taylor had authority (or Rankin later ratified Taylor’s signing); the circuit court denied the motion, finding Taylor lacked authority when she signed and that ratification was not proven.
The Court of Appeals affirmed, holding no agency existed at signing and Progressive failed to prove Rankin’s knowledge necessary for ratification.

Issue	Plaintiff's Argument (Taylor)	Defendant's Argument (Progressive)	Held
Whether Taylor’s signature bound Rankin to arbitration	Taylor lacked authority on Feb 23 and did not bind Rankin	Taylor signed admission and arbitration on behalf of Rankin; agreement should bind Rankin	Held: No—Taylor had no authority on Feb 23, so Rankin was not bound
Whether Rankin impliedly ratified Taylor’s signing after admission or by later conduct	No agency existed at signing; ratification inapplicable; no proof Rankin knew of the signing	Rankin accepted benefits (care), later executed POA, and did not rescind—so ratification should be implied	Held: No—ratification requires an agency at signing and principal’s knowledge; Progressive presented no evidence Rankin knew of Taylor’s signing

Courtyard Gardens Health & Rehab., LLC v. Quarles, 428 S.W.3d 437 (Ark. 2013) (one who lacks authority when signing cannot bind principal to arbitration)
Hickory Heights Health & Rehab, LLC v. Taylor, 596 S.W.3d 536 (Ark. Ct. App. 2020) (adult child lacked authority to bind mother to arbitration in nursing‑home admission)
Brady v. Bryant, 894 S.W.2d 144 (Ark. 1995) (ratification is express or implied adoption by the principal of unauthorized acts)
Arnold v. All Am. Assur. Co., 499 S.W.2d 861 (Ark. 1973) (implied ratification may be inferred from principal’s acts and words but requires knowledge)
Runyan v. Comm. Fund of Little Rock & North Little Rock, 31 S.W.2d 743 (Ark. 1930) (a contract by a non‑agent cannot be ratified)
Sterne, Agee & Leach v. Way, 270 S.W.3d 369 (Ark. Ct. App. 2007) (ratification permits principal to adopt unauthorized contract by agent)