Melinda M. Binkley, Trustee on behalf of the heirs and next of kin of Kirk T. Lloyd, II v. Allina Health System, 2016 Minn. LEXIS 169

Background

In May 2010, 17-year-old Kirk Lloyd sought voluntary inpatient psychiatric admission to United Hospital after self-injury and expressing suicidal intent; hospital staff initially indicated admission but later released him the same day.
Lloyd died by suicide within 48 hours after discharge; his mother, Binkley, sued Allina/United and treating staff for medical malpractice alleging negligent evaluation, admission decision, and post-discharge care.
Respondents moved for summary judgment asserting statutory immunity under Minn. Stat. § 253B.23, subd. 4 (part of the Minnesota Commitment and Treatment Act, CTA); district court denied that motion.
The court of appeals reversed, holding the CTA immunity covers voluntary-admission decisions; the Minnesota Supreme Court granted review.
The Supreme Court interpreted § 253B.23, subd. 4 to provide immunity to persons acting in good faith “who act pursuant to any provision of this chapter,” and therefore held the hospital’s good-faith decision not to admit Lloyd is entitled to immunity.
The court remanded because some of Binkley’s claims (e.g., care provided after discharge) may survive immunity and thus summary judgment on all claims was not necessarily warranted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Minn. Stat. § 253B.23, subd. 4 grant immunity for good-faith decisions declining voluntary admission?	Binkley: immunity is limited to the involuntary-commitment process; it does not cover voluntary admission denials.	Respondents: the statute’s plain language extends immunity to anyone acting in good faith pursuant to any provision of the CTA, including voluntary-admission decisions.	The court held the provision unambiguously covers persons who act in good faith pursuant to any provision of the CTA, so the good-faith admission decision is entitled to immunity.
Does the phrase modifying "procedurally or physically assist" limit immunity to commitment-related acts only?	Binkley: the limiting phrase "in the commitment of any individual" should modify the whole clause, restricting immunity to commitment-related acts.	Respondents: grammar and the disjunctive "or" show the phrase modifies only the assistance clause, creating two distinct categories.	The court applied the last-antecedent rule and gave "or" its ordinary disjunctive meaning; it rejected Binkley’s narrowing reading.
Do specific immunity provisions elsewhere in the CTA make § 253B.23, subd. 4 redundant or inappropriate to apply broadly?	Binkley: broad reading would render other, specific immunity provisions unnecessary and expand immunity beyond legislative intent.	Respondents: overlapping immunities can exist; § 253B.23 is textually broad and controls.	The court found overlap does not override plain statutory text and declined to narrow § 253B.23 on policy grounds.
Does statutory immunity resolve all of Binkley’s malpractice claims?	Binkley: claims about inadequate post-discharge care and other acts may not be covered by CTA immunity.	Respondents: sought summary judgment on all claims based on § 253B.23.	The court held immunity applies to the good-faith admission decision but remanded because post-discharge care decisions may not be covered; summary judgment on all claims is not compelled.

Key Cases Cited

Kastner v. Star Trails Ass’n, 646 N.W.2d 235 (Minn. 2002) (procedural precedent for taking an interlocutory appeal)
Enberg v. Bonde, 331 N.W.2d 731 (Minn. 1983) (discussed predecessor statutory immunity in context of emergency hold)
Cairl v. State, 323 N.W.2d 20 (Minn. 1982) (government-official immunity after discharge of patient who later started a fire)
Larson v. State, 790 N.W.2d 700 (Minn. 2010) (applying grammatical rule of last antecedent to statutory modifiers)
Amaral v. Saint Cloud Hosp., 598 N.W.2d 379 (Minn. 1999) (context cited on interpreting conjunctive/disjunctive readings of "or")