Law School Case Brief
Muse v. Charter Hosp. - 117 N.C. App. 468, 452 S.E.2d 589 (1995)
The doctrine of superseding, or intervening, negligence is well established in our law. In order for an intervening cause to relieve the original wrongdoer of liability, the intervening cause must be a new cause, which intervenes between the original negligent act and the injury ultimately suffered, and which breaks the chain of causation set in motion by the original wrongdoer and becomes itself solely responsible for the injury. The intervening cause must be an independent force which turns aside the natural sequence of events set in motion by the original wrongdoer and produces a result which would not otherwise have followed, and which could not have been reasonably anticipated. The rule in this jurisdiction is that except in cases so clear that there can be no two opinions among fair-minded people, the question should be left for the jury to determine whether the intervening act and the resultant injury were such that the original wrongdoer could reasonably have expected them to occur as a result of his own negligence.
On 12 June 1986, Delbert Joseph Muse, III ("Joe"), who was sixteen years old at the time, was admitted to Charter Hospital for treatment related to his depression and suicidal thoughts. Joe's treatment team consisted of Dr. Barnhill, as treating physician, Fernando Garzon, as nursing therapist, and Betsey Willard, as social worker. During his hospitalization, Joe experienced auditory hallucinations, suicidal and homicidal thoughts, and major depression. Joe's insurance coverage was set to expire on 12 July 1986. As that date neared, Dr. Barnhill decided that a blood test was needed to determine the proper dosage of a drug he was administering to Joe. The blood test was scheduled for 13 July, the day after Joe's insurance was to expire. Dr. Barnhill requested that the hospital administrator allow Joe to stay at Charter Hospital two more days, until 14 July. Joe’s parents, Mr. and Mrs. Muse, signed a promissory note to pay for the two extra days. The test results did not come back from the lab until 15 July. Nevertheless, Joe was discharged on 14 July and was referred by Dr. Barnhill to the Guilford County Area Mental Health, Mental Retardation and Substance Abuse Authority ("Mental Health Authority") for outpatient treatment. Mr. and Mrs. Muse’s evidence tended to show that Joe's condition upon discharge was worse than when he entered the hospital. Defendant Charter Hospital of Winston-Salem, Inc.’s ("Charter Hospital") evidence, however, tended to show that while his prognosis remained guarded, Joe's condition at discharge was improved. Upon his discharge, Joe went on a one-week family vacation. On 22 July, he began outpatient treatment at the Mental Health Authority, where he was seen by Dr. David Slonaker, a clinical psychologist. Two days later, Joe again met with Dr. Slonaker. Joe failed to show up at his 30 July appointment, and the next day he took a fatal overdose of Desipramine, one of his prescribed drugs. Mr. and Mrs. Muse filed an action against the hospital and medical corporation for the wrongful death of Joe. The Superior Court granted compensatory and punitive damages to Joe’s estate.
Did the lower court err in its judgment of liability and awards of punitive damages against Charter Hospital and its parent corporation?
The Court of Appeals of North Carolina found that Joe had committed suicide after being discharged from Charter Hospital. The court affirmed the compensatory award, but reversed and remanded the punitive awards. After concluding that Charter Hospital had a duty not to institute a policy or practice which required that patients be discharged when their insurance expired and which interfered with the medical judgment of the doctor, the court found sufficient evidence that the hospital's practices were below this standard of care and were willful or wanton. The court determined, however, that the trial court had erred in instructing the jury that it could impose punitive damages against both the hospital and parent corporation because after finding that the hospital was an instrumentality of the parent corporation, the two should have been treated as one in assessing liability. In this case of first impression in the state, the court also adopted the rule that where a psychiatric hospital has assumed the care of a suicidal patient, and as a result of its negligence, the patient commits suicide, the hospital cannot claim that the suicide was a superseding cause, insulating the hospital from liability.
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