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Massachusetts Supreme Court Declines to Hold Hospital Liable for Harm Caused by a Psychiatric Patient Released by a Hospital Physician

If you seek to pursue compensation for personal injuries caused by someone else’s negligence, it is essential to retain an attorney that can identify all parties that may be responsible for your harm and set forth all possible theories of liability, as the failure to do so can be fatal to your claim. The Supreme Court of Massachusetts recently held in Williams v. Steward Health Care System, that a hospital could not be held directly liable for harm caused by a psychiatric patient that was released by his treating physician. While the court noted that it was possible for the hospital to be liable under a theory of vicarious liability, plaintiff did not assert that cause of action. If you suffered injuries due to someone else’s negligence, you should consult with an experienced Massachusetts personal injury attorney to discuss the facts of your case and your options for recovering damages.

Factual Background   

Allegedly, in Williams, the assailant fatally stabbed his neighbor. The assailant had been a patient at the hospital under multiple court orders. The orders directed he was to be committed to the hospital due to mental illness until there was no longer a danger of serious harm due to his illness, for up to six months. The assailant was admitted for twenty-one days, after which the doctor treating the assailant purportedly determined he no longer posed a risk of harm due to his mental illness and discharged the assailant. Approximately three weeks after his release the assailant allegedly broke into his neighbor’s apartment and fatally wounded her.

Reportedly, plaintiff, the personal representative of the victim’s estate, sued the hospital alleging wrongful death, emotional distress, negligence in violating the terms of a civil commitment, and loss of consortium. Plaintiff alleged that the hospital breached a duty of care by releasing the assailant from involuntary commitment. The hospital filed a motion for summary judgment, arguing it did not owe plaintiff a duty of care. The court agreed with the hospital, granting its motion. Plaintiff appealed. On appeal, the Supreme Court of Massachusetts affirmed the lower court ruling.

Massachusetts Supreme Court Ruling

On appeal, plaintiff argued the hospital had a duty imposed by the civil order, which required the hospital to commit the assailant. Further, plaintiff alleged the hospital could not delegate this duty to the treating physician. The court disagreed, finding that the duty to determine whether the assailant was well enough to be discharged rested solely with the treating physician. The court noted that an opinion by a mental health professional is required to order an involuntary psychiatric commitment. Subsequently, a mental health professional may also determine that it is appropriate to release a psychiatric patient.

The court noted that the laws regarding involuntary commitment did not impose an obligation on the hospital for the treatment of a psychiatric patient who was admitted through a court order or require the hospital to assess the appropriateness of the patient’s release. The court did state, however, that a hospital could be held liable via its employment relationship with the treating physician, but noted that the plaintiff did not assert any claims of vicarious liability or any claims against the assailant’s treating physician, as needed to recover.

The court also declined to find the hospital owed a duty to protect third parties, noting Massachusetts law specifically stated there is no duty to protect third parties except in very limited circumstances that did not exist in this case. Rather, the court held that the duty to hold the assailant came from the court order and when the treating physician determined the assailant no longer posed a risk of harm the hospital no longer had authority to keep the assailant.

Confer with an Experienced Massachusetts Personal Injury Attorney

If you were injured due to someone else’s negligence, you might be able to recover damages. It is essential to your recovery that you retain an attorney experienced in litigating personal injury cases, to ensure your case is handled properly. The personal injury attorneys at Karsner & Meehan have the knowledge and experience needed to assist you in obtaining a successful outcome. Contact us at 508-822-6600 or via our online form for a free consultation.

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