City of Richmond Hill v. Maia, 301 Ga. 257

In Feb 2011, 14-year-old Sydney Sanders attempted suicide and officers, including Officer Douglas Sahlberg, photographed her injuries at the hospital.
Sahlberg later accessed the photos on his work computer and showed them to his daughter, a classmate of Sanders; the images were then circulated among students and caused Sanders significant humiliation and distress.
On April 5, 2011, RHPD officers responded to Sanders’ home; later that evening, Sanders was left alone and died by suicide.
Maia (the mother) sued the City and Sahlberg (official and individual capacities) for wrongful death and related claims, alleging breach of a duty to keep the photos confidential and that the breach proximately caused Sanders’s suicide.
Defendants moved for summary judgment arguing that suicide is generally an unforeseeable, intervening act breaking causation; the trial court denied the motion, the Court of Appeals affirmed (plurality), and the Georgia Supreme Court granted certiorari.
The Georgia Supreme Court reversed the Court of Appeals, holding that (absent narrow exceptions) suicide is an intervening act as a matter of law that severs proximate cause, and the exceptions did not apply here.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants’ negligent disclosure of injury photos proximately caused Sanders’s suicide	Maia: foreseeability of suicide makes proximate cause a jury question; Sahlberg’s disclosure foreseeably led to suicide	Defendants: suicide is generally an unforeseeable, intervening act breaking causation; exceptions don’t apply	Held for defendants: suicide severs proximate cause as a matter of law here
Whether the rage-or-frenzy exception applies	Maia: emotional distress from photo dissemination made suicide foreseeable/impulsive	Defendants: evidence shows distress but not insanity, uncontrollable impulse, or involuntary act required for the exception	Held: rage-or-frenzy exception does not apply
Whether a special-relationship (duty to prevent suicide) existed between Sahlberg and Sanders	Maia: defendants’ conduct and policy obligations created a duty to protect Sanders	Defendants: no custody, control, or traditional doctor/patient or jailer relationship existed	Held: no special-relationship here; exception inapplicable
Whether foreseeability alone can overcome the general rule that suicide is an intervening cause	Maia: foreseeability governs proximate cause questions and should defeat summary judgment	Defendants: Georgia law treats suicide as unforeseeable intervening cause except in narrow exceptions; foreseeability alone insufficient	Held: foreseeability alone insufficient; exceptions required and not met

Johnson v. Am. Nat. Red Cross, 276 Ga. 270 (2003) (elements of negligence: duty, breach, causation, damages)
Atlanta Obstetrics & Gynecology Grp., P.A. v. Coleman, 260 Ga. 569 (1990) (plaintiff must prove cause in fact and proximate cause)
Brandvain v. Ridgeview Inst., Inc., 188 Ga. App. 106 (1988) (foreseeability central to proximate cause analysis)
McQuaig v. McLaughlin, 211 Ga. App. 723 (1994) (doctrine of intervening causes and foreseeability)
Dry Storage Corp. v. Piscopo, 249 Ga. App. 898 (2001) (recognizing rage-or-frenzy exception to suicide-as-intervening-cause rule)
Stevens v. Steadman, 140 Ga. 680 (1913) (suicide generally not the legal and natural result of prior acts; potential separate exception for aiding/counseling suicide)
Elliott v. Stone Baking Co., 49 Ga. App. 515 (1934) (rage-or-frenzy applied where physical injury produced insanity and involuntary suicide)
Purcell v. Breese, 250 Ga. App. 472 (2001) (special-relationship duty in doctor-patient/hospital context)
Kendrick v. Adamson, 51 Ga. App. 402 (1935) (special duty of custody: officer/jailer to detainee/prisoner)
Williams v. Grier, 196 Ga. 327 (1943) (foreseeability maintains causal connection when intervening acts are foreseeable)