On April 14, 2022, the Virginia Supreme Court opined that the beneficiary of a trust was not subject to the trust’s arbitration provision under the Virginia Uniform Arbitration Act or the Federal Arbitration Act for two independent reasons: (1) a trust is not a contract; and (2) “the beneficiary of a trust is not party to a written [arbitration] agreement,” i.e., “has not agreed to submit the case to arbitration”. Id. at 6 (emphasis original). That second prong supports wrongful death beneficiaries and other third parties in medical malpractice cases not being bound by arbitration provisions in nursing home and other healthcare provider agreements with their patients. The case is Boyle v. Anderson, Record No. 210382.