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.2015Background
- 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)
