Pennsylvania Superior Court Reviews Immunity Provisions of Mental Health Procedures Act in Case of Voluntary In-Patient Examinations

In the case of Matos v. Geisinger Medical Center, No. 1189 MDA 2021 (Pa. Super. March 10, 2023 Stabile, J., Bender, P.J.E., Stevens, P.J.E.) (Op. by Stabile, J.), the court, addressing an interlocutory appeal that was allowed by permission, affirmed the trial court's denial of the Defendant's motion for summary judgment in a medical malpractice case involving the application of the Mental Health Procedures Act.

The Superior Court agreed that a Defendant is not absolutely immunized from a Plaintiff’s lawsuit under the Mental Health Procedures Act.

According to the Opinion, in this matter, the Defendants allegedly refused a patient’s attempt to commit himself voluntarily for in-patient treatment and, shortly thereafter, that patient killed his girlfriend, who was the Plaintiff’s decedent.

The court found that the immunity requirements under the Mental Health Procedures Act are different for involuntary and voluntary treatment scenarios.

The Pennsylvania Superior Court ruled that mental health facilities can be liable for the refusal to provide voluntary in-patient examinations and treatment when the refusal amounts to a willful misconduct or gross negligence on the part of the Defendant.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney James M. Beck of the Philadelphia law office of the Reed Smith law firm.