A seventeen-year-old boy presented to a hospital’s emergency room seeking to be admitted for voluntary inpatient mental health treatment. A licensed professional counselor performed an initial mental-health assessment of the teen. A medical doctor also performed a physical screening on the boy. Both agreed that he should be admitted to the mental-health-care unit. The boy spent most of the day awaiting admission to the hospital's inpatient mental-health-care unit.
That afternoon, however, hospital staff determined that the boy would not be admitted to inpatient care. Hospital staff discussed outpatient options with the boy, set up an appointment with his school therapist for the following day, and had him sign a discharge recommendation, which included a statement indicating that he was not a danger to himself or anyone else. Shortly after being denied admission to the hospital's inpatient mental-health-care unit, the boy committed suicide.
The teen’s mother sued the hospital for medical negligence. The hospital moved for summary judgment on the ground that the immunity provisions of the Minnesota Commitment and Treatment Act (CTA) applied. The CTA outlined the procedures for voluntary admissions, involuntary commitments, and emergency holds of persons suffering from mental illness. The CTA provision governing voluntary admissions stated that “[a]ny person 16 years of age or older may request to be admitted to a treatment facility as a voluntary patient for observation, evaluation, diagnosis, care and treatment without making formal written application.” Minn. Stat. § 253B.04, subd. 1. The CTA also contained an immunity provision, which stated, “All persons acting in good faith, upon either actual knowledge or information thought by them to be reliable, who act pursuant to any provision of this chapter or who procedurally or physically assist in the commitment of any individual, pursuant to this chapter, are not subject to any civil or criminal liability under this chapter.” Minn. Stat. § 253B.23, subd. 4 (2014).
The trial court refused to grant the hospital summary judgment.
The Court of Appeals of Minnesota reversed. The court held that the immunity provisions of the CTA applied to voluntary admissions.
The immunity provisions of the CTA applied to voluntary admissions. The plain language of the CTA immunity provision protects two groups of people: (1) those “who act pursuant to any provision of [chapter 253B]” or (2) those “who procedurally or physically assist in the commitment of any individual.” The court explained that because the boy was refused admission pursuant to the voluntary admission procedures stated in the CTA’s section 253B.04, the immunity provision applied. Voluntary admissions qualify for immunity under the “any provision of this chapter” language of the statute.
The Court of Appeals of Minnesota reversed the trial court and held that the hospital was immune from suit for acting pursuant to the voluntary admission procedure in the CTA.
See: Binkley v. Allina Health System, et al., 2015 WL 506623 (Minn.App., February 9, 2015) (not designated for publication).
See also Medical Law Perspectives, December 2014 Report: Beyond the Holiday Blues: When Depression Leads to Liability