Pennsylvania Supreme Court: Mental Health Facilities May Be Liable for Gross Negligence in Denying Voluntary Admission
Matos v. Geisinger Med. Ctr., 334 A.3d 288 (Pa. 2025)
An individual with an extensive mental health history sought admission to two different mental health facilities for inpatient psychiatric care. However, both facilities denied his request. Shortly after, he killed his girlfriend. The estate of the victim brought suit against the facilities, alleging their denials met the threshold for gross negligence or willful misconduct pursuant to the voluntary-care provisions of the Mental Health Procedures Act (MHPA).
The Pennsylvania Supreme Court found that written consent to voluntary admission into a mental health care facility for inpatient treatment was not a prerequisite to impose liability against health care providers under the MHPA. For involuntary commitment, prior cases, such as Leight, have held that no liability arises unless a formal written application is completed. However, for voluntary admission, the court reasoned that the act of seeking treatment itself is sufficient to trigger the facility’s duty to evaluate and respond reasonably. However, liability attaches only when the denial of voluntary admission constitutes gross negligence.
Hospital Owed Duty of Care Through Pre-Transfer Involvement, Pennsylvania Court Affirms
Munoz v. Children’s Hosp. of Philadelphia, No. 1388 EDA 2024, 2025 WL 1504354 (Pa. Super. Ct. May 27, 2025)
The Superior Court of Pennsylvania affirmed the judgment entered by the Court of Common Pleas of Philadelphia County, which found that CHOP had undertaken and provided health care services to a minor decedent and, therefore, owed him a duty of care.
The plaintiffs, the parents of the minor decedent, brought suit against Einstein Medical Center and CHOP. The decedent was treated at Einstein Medical Center, who contacted CHOP for assistance. CHOP opened a chart for the decedent and dispatched a transport team to Einstein. Upon arrival, the decedent deteriorated rapidly, and CHOP nurses provided treatment to the decedent, guided by a CHOP physician who was providing instructions over the phone. However, the decedent suffered cardiac arrest and passed away before transfer to CHOP.
The Superior Court affirmed that CHOP assumed a patient relationship by advising on treatment, opening a chart, dispatching a transfer team and providing emergency care. As such, they created a duty to exercise reasonable care. Hospitals may assume liability when they become involved in the care and treatment of a patient, even if it is indirectly through telephone guidance and dispatch of staff. CHOP entered a physician-patient relationship with the decedent for treatment purposes because of CHOP’s active participation in the care of decedent prior to the transport team arrived at Einstein, and the continued services provided by the CHOP team upon arrival.
Superior Court Reverses Nonsuit, Holds Trial Court Bound by Prior Ruling on Expert Qualification
Joyner v. Thomas Jefferson Univ. Hosps., Inc., No. 534 EDA 2024, 2025 WL 933175, at *1 (Pa. Super. Ct. Mar. 26, 2025), reargument denied (May 29, 2025)
In her suit, the pro se plaintiff alleged negligent placement of leg restraints during gall bladder surgery. As she alleged a deviation from the professional standard of care, she was required to file a certificate of merit pursuant to Rule 1042.3.
The appellate court previously ruled that the plaintiff’s expert was an “appropriate licensed professional” under Rule 1042.3(e). Prior to trial, the defendant moved to exclude the plaintiff’s expert testimony regarding the standard of care, and the trial court limited his testimony solely to causation. The trial court granted a compulsory nonsuit, finding that the plaintiff lacked a duty breach.
The Superior Court reversed the nonsuit, finding that once the court accepted the plaintiff’s expert as a qualified expert, the trial court was bound to that determination.
This decision highlights issue preclusion; once an appellate court determines an expert is qualified, lower courts cannot re-litigate this issue.
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