Maxwell v. Atria Management Co., LLC

Holding

The court held that the trial court erred in denying the Atria defendants’ motion to compel arbitration because the arbitration agreement’s enforceability must be evaluated in light of the California Supreme Court’s decision in *Harrod v. Country Oaks Partners, LLC* (2024) 15 Cal.5th 939, which limits a power‑of‑attorney holder’s authority to bind a principal to arbitration when the power‑of‑attorney is limited to health‑care decisions. Accordingly, the appellate court reversed and remanded for the trial court to determine (1) whether the durable power of attorney (DPOA) presented by James Maxwell III was valid, (2) whether the arbitration agreement was enforceable under the facts, and (3) whether the separate health‑care POA held by Marybeth Maxwell conferred authority to admit the decedent to Atria and to bind the estate to arbitration. The court also affirmed that the children’s wrongful‑death claims are not subject to arbitration because they are non‑signatory third parties, and it declined to find Federal Arbitration Act preemption of California Code of Civil Procedure § 1281.2(c). ---