Superior Court Finds No Duty Owed By Methadone Clinic to Public At Large Where Client Allegedly Drove Intoxicated and Caused Injury

In the case of Ritz v. Ramsay, No. 1024 WDA 2022 (Pa. Super. Nov. 14, 2023 Bender, P.J.E., Stabile, J., and Pellegrini, J.) (Op. by Stabile, J.), the Pennsylvania Superior Court ruled that the trial court properly dismissed and executor’s action against medical center parties that allegedly gave methadone to a driver of a car who allegedly then killed the decedent in a Christmas Eve, 2016 motor vehicle accident.  The decedent was out for a run when he was hit and killed.  

The Superior Court found that the trial court did not err in declining to impose a duty of care on the medical center parties, particularly where there was no relationship between the decedent and the medical center parties.

According to the Opinion, the decedent was struck by a car and killed after the driver, who was a patient at the Defendant medical center’s methadone clinic, had allegedly received a larger than normal dose of methadone on the day of the accident.

The records show that the driver’s post-accident blood and urine samples also showed the presence of marijuana and alprazolam in addition to the methadone.

According to the Opinion, the medical center parties were alleged to have been aware, based upon prior blood tests, that the driver repeatedly used non-prescription anti-anxiety drugs and marijuana during the course of his methadone treatment, which conduct was in violation of the directives of the methadone center.

The Plaintiffs asserted that the medical center parties knew or should have known that given the driver a larger than normal dose of methadone posed an unreasonable risk to the public. As such, the Plaintiff sued for negligence under the wrongful death statute.

The Pennsylvania Superior Court noted that there were no allegations that the medical center parties knew that the driver drove while intoxicated as a result of his ingesting of other substances along with his methadone.  As such, the appellate court agreed that the foreseeability of this tragedy was too remote to impose a duty under Pennsylvania law.

The appellate court additionally noted that imposing liability in this regard would not serve the public interest in view of the lack of foreseeability and given the strong public interest in the rehabilitation of users of elicit drugs through, in part, methadone clinics.

The Superior Court also ruled that the trial court was within its discretion not to allow the Plaintiff the right to amend given that, under the facts, circumstances, and the law of this case, any effort at filing an Amended Complaint would have been futile.

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


Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Dec. 7, 2023).