Holland v. Silverscreen Healthcare, Inc.

Summary

The court held that a patient’s MICRA-compliant arbitration agreement binds heirs bringing a wrongful death claim only when the claim concerns negligent provision of medical services. Claims alleging a skilled nursing facility’s failure to provide custodial care, basic necessities, or routine safety protection fall outside that arbitration exception. Because the complaint did not specify whether the alleged falls and infections resulted from medical malpractice or custodial neglect, the court reversed and remanded to allow amendment. No separate opinions were filed.