E-Alert Case Updates

Trial Court Properly Granted Defendant Health Care Providers’ Motions to Dismiss Because They Were Immune From Liability Under Involuntary Admittance Statute, MD. CODE ANN, HEALTH GEN. § 10-618

Williams v. Peninsula Regional Medical Center
No. 18 (Maryland Court of Appeals, November 21, 2014)
by Colleen K. O’Brien, Associate
Semmes, Bowen & Semmes (www.semmes.com)

Available at: http://www.mdcourts.gov/opinions/coa/2014/18a14.pdf

SUMMARY: Trial Court properly dismissed wrongful death action on basis of statutory immunity, since state law provides immunity against negligence-based suits based on involuntary-admission decisions. While Section 10-618 of the Maryland Health-General Article is written in terms of the decision to admit a patient against his or her will, it is sound public policy and consistent with the legislative intent to apply the section to decisions against involuntary admission, so that doctors can be guided by their judgment and not fear of liability.

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In Williams v. Peninsula Regional Medical Center, No. 18 (Court of Appeals of Maryland, November 21, 2014), Charles Williams, Jr. (“Mr. Williams”), age 34, was brought to Peninsula Regional Medical Center (“PRMC”) by his mother, Gineene Williams (“Ms. Williams”). Mr. Williams was suffering from suicidal ideation and auditory and visual hallucinations. After evaluating Mr. Williams, health care providers decided not to admit him for psychiatric treatment and discharged him to the care of his mother. Immediately after discharge, Mr. Williams escaped from his mother’s care. That same night, he was killed by law enforcement officers after inviting the officers to shoot him, and then aggressively rushing them. Thereafter, Ms. Williams and other family members filed a wrongful death and survivorship action against PRMC and the health care providers who treated Mr. Williams there (collectively, “Defendants”). The issue before the Court was whether the Defendants had statutory immunity in the decision to release, rather than involuntarily admit, the young man to the hospital.

At the trial Court level below, in response to Plaintiffs’ negligence claims, the Defendants filed Motions to Dismiss, arguing that the Complaint failed to state a claim upon which relief could be granted, that they were entitled to statutory immunity, and that the Complaint failed to assert that the actions of the health care providers were the proximate cause of Mr. Williams’ injuries. After hearing arguments, the Circuit Court granted the Motions to Dismiss, concluding that the Defendants were protected from liability by statutory immunity. The Plaintiffs appealed to the Court of Special Appeals, which affirmed the trial court decision. See Williams v. Peninsula Reg’l Med. Ctr., 213 Md. App. 644, 75 A.3d 359 (2013).

Maryland’s highest court, the Court of Appeals, granted certiorari to determine whether the Maryland involuntary admission immunity statute, MD. CODE ANN., HEALTH GEN. § 10-618, applies to health care providers who evaluate an individual and decide to discharge the patient from psychiatric care. The Court determined that the involuntary admission statute did apply to Defendants, and affirmed the judgments of the courts below.

First, § 10-618 provides immunity to certain groups who participate in the involuntary admission process, including a “facility” like PRMC, as well as the individual health care providers who qualify by virtue of being agents or employees of the facility. Therefore, the plain language of § 10-618 extended immunity to Defendants. The inquiry did not end there, however.

The Court next considered whether § 10-618 applied when the evaluation did not lead to involuntary admission. The Plaintiffs urged a narrow reading of the statute based on its title. Plaintiffs argued that the immunity only applied when an individual is admitted for treatment. Here, Mr. Williams was evaluated but discharged. The Court disagreed with Plaintiffs’ interpretation of the statute, however, and determined that based on the statutory text, the immunity extended beyond circumstances in which an individual is involuntarily admitted. It did not matter that the statutory captions did not specifically refer to instances in which the decision is not to admit an individual.

Further, cloaking health care providers in immunity both when they decide in favor of, or when they decide against admittance, amounted to sound public policy, consistent with the Legislature’s intent. The legislation itself, passed in 1982, was prompted by changing attitudes about mental illness and the statute was aimed at preventing excessive institutionalization and protecting the civil rights of patients. To determine that the immunity provision only applied to circumstances where the patient was involuntarily admitted would run against the legislative intent and public policy. The legislative intent was to protect individuals from undue deprivation of liberty and it would make little sense to give health care providers an incentive to err on the side of involuntary admittance to receive a statutory immunity and avoid liability. Instead, the statutory scheme protected the discretion of health care providers tasked with deciding whether to involuntarily admit an individual.

Accordingly, the Court held, based on the plain language of the text, the legislative intent, and public policy that the involuntary admission immunity statute codified at MD. CODE ANN, HEALTH GEN. § 10-618 extended to health care providers who evaluated an individual and decided in good faith not to involuntarily admit him or her. The Court affirmed the judgment of the Court of Special Appeals and the trial court in determining that the Defendants’ Motion to Dismiss was properly granted on the basis of statutory immunity.