McGuire v. Almy

297 Mass. 323, 8 N.E.2d 760 (1937)

 

RULE:

Where an insane person by his act does intentional damage to the person or property of another she is liable for that damage in the same circumstances in which a normal person would be liable. This means that in so far as a particular intent would be necessary in order to render a normal person liable, the insane person, in order to be liable, must have been capable of entertaining that same intent and must have entertained it in fact. But the law will not inquire further into her peculiar mental condition with a view to excusing her if it should appear that delusion or other consequence of her affliction has caused her to entertain that intent or that a normal person would not have entertained it.

FACTS:

Plaintiff was a nurse employed to take care of defendant, an insane patient. Defendant injured plaintiff when she tried to prevent defendant from injuring herself during a violent rage. Plaintiff sued defendant in an action for tortious assault and battery. The trial court denied defendant's motion for a directed verdict, and entered judgment in favor of plaintiff based upon a jury verdict. On appeal, the state supreme court affirmed, because it determined the jury could find that the defendant was capable of entertaining and that she did entertain an intent to strike and to injure the plaintiff and that she acted upon that intent. Because defendant had the requisite intent, the state supreme court reasoned, despite her insanity, defendant was liable for damages resulting from her intentional acts.

ISSUE:

Can an insane person be held liable for his acts that cause injury to other or damage to property?

ANSWER:

Yes.

CONCLUSION:

Judgment for plaintiff affirmed, because the jury could find defendant entertained an intent to strike and injure plaintiff and that defendant acted on that intent, and because defendant did intentional damage to the person of another she was liable for that damage even though insane.

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