Expert Testimony Required To Show Causation in Wrongful Death Action For Failure To Commit Suicidal Patient

A man expressed suicidal thoughts during a conflict with his family, resulting in the man being transported to the defendant hospital’s emergency room. The defendant treating physician assessed him and, at the man’s request, discharged him. Thirty-six hours after he was discharged from the defendant’s emergency room, the man committed suicide. 


The man’s family brought a wrongful death action against the doctor and, under respondeat superior, the hospital. At trial, the jury found the doctor had not been negligent. The court then granted the hospital’s motion for a judgment as a matter of law because the plaintiffs failed to meet their burden with respect to proximate cause.


The Rhode Island Supreme Court affirmed the trial court’s decision holding that expert testimony was required to establish proximate cause. The court reasoned that it would not have been obvious to a lay person what would most probably have resulted if the treating physician had committed the suicidal man, both in relation to the commitment procedure and the man’s mental health.


See: Almonte v. Kurl, 2012 WL 2395260 (R.I., June 26, 2012) (not designated for publication).