Gould v. Am. Family Mut. Ins. Co.

523 N.W.2d 295

 

RULE:

An individual suffering from a permanent mental disability that prevents the individual from controlling or appreciating the consequences of his or her conduct is precluded from negligence.

FACTS:

A nurse was injured when a resident patient pushed and struck her. She then brought an action for personal injuries. At trial, the jury was instructed to determine liability without considering the patient’s mental status. The trial court returned a verdict for the plaintiff, finding the patient causally negligent.

ISSUE:

Can a person be held civilly liable where a mental condition deprives them of the ability to control their own behavior?

ANSWER:

No, a person who cannot control their behavior due to a permanent mental condition cannot be held civilly liable.

CONCLUSION:

The court held that a person’s mental condition can deprive them of the ability to be negligent. If the individual is suffering from a permanent mental disability that prevents them from controlling or appreciating the consequences of their actions, they are precluded from negligence. However, a sudden mental deficiency will not absolve a defendant of liability. Here, the trial court instructed the jury to ignore the defendant’s mental condition. The appellate court held that was a reversible error.

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