Brenda Ramsey v. Cocke County, Tennessee, E2016-02145-COA-R3-CV

Brenda Ramsey sued Cocke County Emergency Communications District (ECD) and the City of Newport/Newport Police Department after her daughter Rebecca threatened suicide by ~8:30 p.m. and later died by suicide that night.
Ramsey alleges she called 9-1-1 twice requesting an officer because Rebecca threatened self-harm and was violently damaging property; she alleges dispatch and a Newport officer refused to send responders, citing a policy of not responding to "domestic" calls.
Ramsey drove to the police station but found it locked and no officers present; returning home, she discovered Rebecca had killed herself.
Defendants disputed Ramsey’s version, denying she reported suicide threats or requested an officer, and claimed ECD promptly connected her to police; factual disputes arose in depositions.
At summary judgment the trial court granted defendants’ motions, holding Rebecca’s suicide was an independent, superseding intervening cause and that exceptions (e.g., custodial/special relationship) did not apply.
On appeal the Court of Appeals reversed: viewing facts favorably to Ramsey, suicide was foreseeable and the special-duty exception to the public-duty doctrine (reckless misconduct) could apply, so summary judgment was improper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the decedent's suicide was an independent superseding intervening cause defeating proximate cause	Ramsey: suicide was foreseeable from defendants' alleged refusal to send help after explicit suicide threats	Defendants: suicide was an independent, deliberate act breaking causal chain, so no proximate cause	Court: viewed in plaintiff's favor, suicide could be foreseeable here; not a superseding cause — summary judgment denied
Whether public duty doctrine bars Ramsey's claims (special-duty exception for reckless misconduct)	Ramsey: dispatcher/officer recklessly disregarded a substantial risk by refusing to send help, so special-duty exception applies	Defendants: public duty shields them absent established exception (custodial/special relationships or other recognized exceptions)	Court: facts permit a finder of fact to conclude reckless misconduct and application of the special-duty exception; public duty does not bar claims at summary judgment

White v. Lawrence, 975 S.W.2d 525 (Tenn. 1998) (suicide is not automatically a superseding cause; foreseeability of suicide from defendant’s conduct controls)
Rains v. Bend of the River, 124 S.W.3d 580 (Tenn. Ct. App. 2003) (explains independent intervening cause doctrine and lists exceptions where suicide may still be attributable to defendant)
Ezell v. Cockrell, 902 S.W.2d 394 (Tenn. 1995) (articulates public duty doctrine and the special-duty exceptions)
McClenahan v. Cooley, 806 S.W.2d 767 (Tenn. 1991) (defines elements of proximate/legal cause in Tennessee negligence law)