Court: Indiana Court of Appeals; November 22, 1998; Indiana; State Appellate Court
John Reid, M.D. appeals a summary judgment favoring defendants Rex Ragsdale, M.D., John K. Browning, Thomas F. Liffick, M.D., William Wooten, M.D., and Deaconess Hospital, Inc. Reid presents three issues, with the primary one being whether the trial court correctly determined that a judge’s approval of his involuntary commitment acted as an efficient intervening cause, thereby absolving the doctors of liability. The court affirms the trial court's decision.
Reid was committed to a mental hospital on January 12, 1995, following actions taken by Dr. Wooten, who initiated the commitment process due to concerns about Reid’s potential danger to himself and others. Dr. Liffick, responding to this request, filled out necessary documentation alleging Reid was mentally ill and dangerous, based on information from Dr. Ragsdale. A judge approved the emergency detention based on Liffick’s account. Reid subsequently filed a medical malpractice lawsuit against the involved doctors and Browning.
The defendants sought summary judgment, arguing that no doctor-patient relationship existed or, if it did, they were not the proximate cause of Reid's injuries. The trial court granted summary judgment, finding no physician-patient relationship and concluding that the judge's approval of the commitment was an efficient intervening cause that shielded the defendants from liability.
In reviewing the summary judgment, it is noted that such a judgment is appropriate when no genuine issues of material fact exist, and the moving party is entitled to judgment as a matter of law. The burden lies with the moving party to demonstrate the absence of genuine issues, and the opposing party must provide specific facts to counter this. The trial court’s findings, while not binding on the appellate court, aid in the review process. The appellate court considers evidence in favor of the nonmoving party without weighing it.
Summary judgment can be upheld based on any supported theory, as per T.R. 56(C). Reid claims the trial court incorrectly determined that the judge's approval of the Application for Emergency Detention was an efficient intervening cause. However, the emergency detention statute (Ind. Code 12-26-5-1 and 2) outlines that an application must include: (1) the applicant's belief that the individual is mentally ill and either dangerous or gravely disabled, and (2) a physician's statement indicating that the individual may be mentally ill and dangerous or gravely disabled. Additionally, a judicial officer must endorse the application.
The trial judge referenced the case Rhiver v. Rietman, which established that the committing judge has the ultimate responsibility in determining the need for mental health treatment, and thus, negligence by a physician does not constitute proximate cause for commitment. Reid's assertion that the judge received negligent or false information from the doctors fails because even if the doctors were negligent, the judge's decision was the final authority. The emergency detention statute facilitates a rapid process for detaining individuals posing harm, without requiring personal knowledge or prior examination by the physician endorsing the application.
Reid did not provide evidence that the statutory criteria for emergency detention were unmet or that the information given to the judge was false or made in bad faith. His claims mainly indicate that the doctors did not examine him prior to the application. The judge found sufficient grounds for emergency detention based on the information presented. Consequently, any alleged negligence by the doctors cannot be seen as the proximate cause of Reid's harm, affirming the trial judge's summary judgment.
Reid did not raise any arguments concerning John K. Browning or Deaconess Hospital, leading to waiver of his claims against them. The judge did not have access to the actual Application for Emergency Detention at the time of approval, as it was after business hours, although emergency commitment procedures allowed for telephone approvals post-3 p.m. The court will assume, without deciding, that a physician-patient relationship existed for the appeal. An affidavit from the judge indicated he believed immediate detention of Reid was necessary.
