710 S.E.2d 67
S.C.2011Background
- In June 2005, Appellant was involuntarily detained for mental health evaluation under SC Code §44-17-410, with a detention order for up to 24 hours.
- Appellant was evaluated and initially admitted to Aurora Pavilion, later transferred to Three Rivers Behavioral Health for treatment.
- Probate court issued Orders for Continued Hospitalization (June 13, 2005) and Continued Treatment (June 21, 2005) after hearings by court-appointed examiners.
- Appellant was discharged to her son on July 20, 2005 following treatment; her doctors varied in assessing incapacity.
- In 2007, Appellant sued for false imprisonment, defamation, and intentional infliction of emotional distress; Respondent moved for summary judgment, which was granted on all claims except conspiracy.
- The Court of Appeals certified the appeal; the circuit court’s summary judgment was affirmed, holding the underlying commitment orders valid and the conduct lawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of underlying commitment orders and timeliness | Argoe argues the June 6 order was void and thus the later orders were invalid | Respondent asserts orders were valid on their face and challenged timely via appellate procedures | Procedurally barred; underlying orders valid; cannot challenge via collateral attack |
| False imprisonment liability | Detention was unlawful absent a valid basis | Detention was pursuant to a valid probate court order | No false imprisonment; detention lawful under valid orders |
| Defamation/public disclosure | Disclosures of psychiatric information were defamatory | Disclosures were privileged and authorized by statute and court orders | Privileged disclosures; not defamatory under statute and case law |
| Intentional infliction of emotional distress | Three Rivers conduct was extreme and outrageous | Actions were reasonable and protected by quasi-judicial immunity | No IIED; conduct reasonable under the involuntary commitment framework |
Key Cases Cited
- Fleming v. Rose, 350 S.C. 488 (2002) (summary judgment standards; favorable view of mapping issues to law)
- Manley v. Manley, 291 S.C. 325 (Ct.App. 1987) (involuntary commitment with immunity for treating professionals; no IIED recovery)
- Erickson v. Jones St. Publishers, L.L.C., 368 S.C. 444 (2006) (defamation elements; qualified privilege when communicating about involuntary commitment)
- Riedman Corp. v. Greenville Steel Structures, Inc., 308 S.C. 467 (1992) (res judicata elements and collateral attack considerations)
- Jones by Robinson v. Winn-Dixie Greenville, Inc., 318 S.C. 171 (Ct.App. 1995) (false imprisonment elements; confinement under process doctrine)