Mealey's (February 28, 2019, 10:55 AM EST) -- BOSTON — A First Circuit U.S. Court of Appeals panel on Feb. 26 certified two questions for the Massachusetts Supreme Judicial Court, asking the state’s high court to determine whether a beneficiary’s wrongful death claim is derivative or independent of a decedent’s wrongful death cause of action and whether the beneficiary’s claim is subject to arbitration under an alternative dispute resolution (ADR) form the beneficiary signed when her mother was admitted into a nursing home (GGNSC Administrative Services LLC, et al. v. Jackalyn M. Schrader, No. 18-1779, 1st Cir., 2019 U.S. App. LEXIS 5648)....