Statutory Immunity of Medical Providers Relating to Involuntary Admissions
December 15, 2014 By Emily F. Belanger
In the case of Williams, et al. v. Peninsula Regional Medical Center, et al., the Court of Appeals of Maryland was tasked with deciding whether hospitals and health care providers enjoy statutory immunity against a wrongful death and survivorship action alleging negligence in the decision to release rather than involuntarily admit a young man, who was suffering from suicidal ideation and auditory and visual hallucinations, to the hospital.
A young man, Charles Williams, Jr., had been suffering from suicidal ideation and auditory and visual hallucinations. He was taken to Peninsula Regional Medical Center by his mother, where he was examined and evaluated. Upon completion of the examination, a decision was made not to admit Mr. Williams. He was discharged to the care of his mother. Following discharge, later that night, Mr. Williams was killed by law enforcement officers after Mr. Williams encountered said officers, invited the officers to shoot him, and then rushed them.
A wrongful death and survivorship action was filed against Peninsula Regional Medical Center and several medical providers alleging negligence. Plaintiffs claimed the Defendants failed to perform appropriate diagnostic tests on Mr. Williams, to admit Mr. Williams, and to properly care for Mr. Williams. The Defendant medical providers filed a Motion to Dismiss arguing that the they were entitled to statutory immunity. The trial court agreed and granted the motion.
After review of Maryland’s involuntary admission immunity statute, Section 10-618 of the Health General Article, which Plaintiffs argued did not include health care providers but only those applying for involuntary admission, the Court of Appeals affirmed the dismissal of the case. The court ruled that the plain meaning of the language of the statutes under review clearly included health care providers who in good faith performed evaluations and chose not to involuntary admit a patient. The court pointed out that any other reading of the statutes would tend to encourage health care providers to involuntarily admit patients for no other reason than to avoid potential liability, something the legislature clearly intended to avoid.
The lawyers at DeCaro Doran would be pleased to help you decipher the various statutes discussed, and provide an opinion as to how they might apply to a situation you are facing.