Court Denies Summary Judgment For Defendant Claiming Immunity Under the Mental Health Procedures Act

In the case of Redos v. UPMC Susquehanna, No. 19-00528 (C.P. Lyc. Co. Sept. 6, 2023 Carlucci, J.), the court denied Defendant medical providers’ Motion for Summary Judgment on a Plaintiff’s claim alleging professional liability regarding the treatment of a patient who was allegedly suffering from a mental illness.

According to the Opinion, the Plaintiff’s decedent sought emergency room treatment for symptoms allegedly stemming from his alleged recent drug use. The decedent was transported to another hospital for medical clearance prior to being admitted to a third facility for in-patient psychiatric treatment.

While at the Defendant’s hospital, the decedent was assessed as suffering from delirium. On his third day at that facility, the decedent exhibited bizarre behavior and jumped off the hospital’s roof, resulting in multiple injuries. The decedent died several years later from unrelated reasons.

This lawsuit was brought relative to the care provided to the decedent. After discovery, the Defendants moved for summary judgment based, in part, on the limited immunity afforded under 50 Pa. C.S.A. §7114 of the Mental Health Procedures Act.

 The court denied the Defendants’ motion where the Plaintiff’s expert opined that the Defendants acted in gross deviation from the standard of care for a patient suffering from delirium.

As a result, the court found that the Defendants could be ineligible to assert the limited immunity afforded under the Mental Health Procedures Act.

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