When health care providers decide to commit someone against their will, they are immune from liability as long as certain steps are undertaken. When a Maryland man - taken to the hospital for erratic behavior -- was killed later that day by police, his family sued the hospital, arguing that health care providers at Peninsula Regional Medical Center (PRMC) were liable for his death because they had failed to take action.
But, Maryland's Court of Special Appeals disagreed with the family, concluding that a statute in Maryland's health laws that gives immunity to health care providers who involuntarily admit an individual also provides immunity to those who decide not to involuntarily admit a patient.
Charles Williams Jr. was killed one night by police officers after breaking into a home, obtaining a knife and charging at police. Earlier that day, Williams had been taken to PRMC by his mother because she was concerned about his mental state. Williams told health care providers that he was communicating with "the Lord" and that his ex-girlfriend had placed a curse on him. PRMC health care providers decided not to involuntarily admit him, although they advised Williams' mother to remove any firearms from the residence.
Williams' family filed a wrongful death/survival action in the Circuit Court for Wicomico County. They sued Dr. Michael P. Murphy, nursing assistant George Stroop and Peninsula Regional Medial Center (health care providers). They said the health care providers were negligent in not admitting Williams and that PRMC's negligence caused his death.
However, PRMC and the health care providers asked the court to dismiss the case, contending for the most part that they were immune from a lawsuit because of Maryland law.
Under Maryland law, health care providers can not be sued when they admit someone against their will if they act in good faith and with reasonable grounds. In addition, certain steps, such as a hearing, must be undertaken.
However, Williams was not admitted. Williams' family argued that Maryland law provides immunity from liability only when there is an involuntary admission. They also contended that the statute applies only to involuntary admission because the caption is labeled "involuntary admission" and also because the phrase appears in other parts of Maryland law.
The trial judge agreed with PRMC and granted its motion to dismiss. The court said the statute applies to any evaluation for involuntary admittance, regardless of whether the health care providers decide to admit or to release the patient.
The family appealed, asking Maryland's intermediate appellate court to review the decision.
The Court of Special Appeals agreed with the trial court. The purpose of the immunity statutes is to protect the discretionary nature of the evaluation so that the medical professionals can be guided by their medical judgment and not the fear of liability, the court noted. To do so, the statute must protect those who decide to involuntarily commit a patient as well as those who decide not to involuntarily commit a patient, the court said.
The court noted that the family's dependence on the caption failed because a heading is not part of the law and captions do not control the plain meaning of the text.
The court also determined that a complaint that solely alleges negligence, such as the complaint in this case, is insufficient to overcome the immunity.
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