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Melinda M. Binkley, Trustee on behalf of the heirs and next of kin of Kirk T. Lloyd, II v. Allina Health System
860 N.W.2d 707
Minn. Ct. App.
2015
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Background

  • Lloyd Lloyd, a 17-year-old, committed suicide after being denied inpatient admission; respondent is his mother, Melinda Binkley, trustee for his heirs
  • Lloyd was at United Hospital emergency room for evaluation after a distressing event involving arson and self-harm threats
  • Initial mental-health assessments by Terri Ulschmid and Dr. Jeffrey Swanson recommended admission; Dr. Frances Go designated as Admitting MD
  • Hospital staff ultimately declined inpatient admission and discussed outpatient options despite indications Lloyd was at risk
  • Dispute centers on whether immunity under Minn. Stat. § 253B.23, subd. 4, applies to the voluntary admission decision under Minn. Stat. § 253B.04
  • Lower court denied summary judgment to appellants; the issue is whether CTA immunity applies to voluntary admissions

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether CTA immunity applies to voluntary admissions Binkley argues immunity should not apply to voluntary admissions Allina argues immunity applies when acting under CTA provisions Yes; immunity applies to voluntary admissions when decision made under CTA procedures

Key Cases Cited

  • Losen v. Allina Health Sys., 767 N.W.2d 703 (Minn. App. 2009) (immunity language applies to act in good faith under CTA)
  • Brua v. Minn. Joint Underwriting Ass'n, 778 N.W.2d 294 (Minn. 2010) (statutory language to ascertain legislature’s intent; plain text controls)
  • Dahlin v. Kroening, 796 N.W.2d 503 (Minn. 2011) (review of summary judgment; de novo application of law)
  • Terwilliger v. Hennepin Cnty., 561 N.W.2d 909 (Minn. 1997) (discussion of official immunity scope; distinguish CTA immunity)
  • Lee v. Fresenius Med. Care, Inc., 741 N.W.2d 117 (Minn. 2007) (statutory interpretation guiding CTA provisions)
  • Lefto v. Hoggsbreath Enters., Inc., 581 N.W.2d 855 (Minn. 1998) (de novo review standard on appeal from summary judgment)
Read the full case

Case Details

Case Name: Melinda M. Binkley, Trustee on behalf of the heirs and next of kin of Kirk T. Lloyd, II v. Allina Health System
Court Name: Court of Appeals of Minnesota
Date Published: Feb 9, 2015
Citation: 860 N.W.2d 707
Docket Number: A14-794
Court Abbreviation: Minn. Ct. App.