Professional Negligence Law Reporter

Williams v. Steward Health Care Sys., LLC, 2018 WL 3851864 (Mass. Aug. 14, 2018).

The Massachusetts Supreme Judicial Court held that a hospital owed no duty of care to the victims of a released patient who later stabbed his neighbor.

Roe, a patient held involuntarily at a hospital under a commitment order, was discharged after his treatingphysician determined he no longer posed a likelihood of serious harm. Approximately three weeks later, Roe broke into Mary Miller’s apartment and fatally stabbed her in the presence of her young granddaughter. Miller’s estate and the mother of her granddaughter sued the hospital, alleging liability for Miller’s wrongful death. Suit alleged negligence, reckless infliction of emotional distress, and loss of consortium. The trial court granted the defendant’s summary judgment motion, holding that the defendant did not owe the plaintiffs a duty of care.

Affirming, the state high court found that the state legislature has determined that qualified mental health professionals are in the best position to determine whether a confined patient poses a threat of serious harm and may do so without notifying the court that issued the commitment. The legislature has not imposed a separate, similar duty on a hospital, the court said, noting that holding a patient who no longer poses a threat of serious harm would violate the patient’s constitutional right to liberty. The court found that a hospital may be liable under a respondeat superior theory for the actions of its medical professionals and may also be held responsible for failing to exercise reasonable care in hiring, training, and supervising its medical professionals; nevertheless, the court found, the plaintiffs here have not raised such claims.

Finally, the court determined that the defendant was not liable under a special relationship theory. The hospital owed a duty to Roe while he was in custody, but this duty was limited to the period of actual custody, the court said. Consequently, the court held that summary judgment for the defense had been proper.