Nguyen v. Massachusetts Institute of Technology
96 N.E.3d 128
Mass.2018Background
- Han Duy Nguyen, a 25-year-old MIT Sloan Ph.D. student, died by suicide on June 2, 2009; plaintiff (his father, administrator) sued MIT, two faculty advisors (Wernerfelt, Prelec), and assistant dean Randall for negligence.
- In 2007 Nguyen sought limited academic help from MIT (test-taking, sleep problems) and briefly met with MIT Mental Health and student support; he repeatedly refused broader MIT clinical services and sought treatment largely from numerous off-campus clinicians.
- Nguyen disclosed prior suicide attempts (2002, 2005) to an MIT psychologist in 2007 but denied current suicidal intent; he revoked permission for the assistant dean to contact his outside psychiatrist.
- Faculty modified Nguyen’s exam schedule and expressed concern about his well-being; five months before his death Wernerfelt used the metaphor “blood on our hands” when urging leniency, but neither faculty member had knowledge of any specific suicide plan.
- On the morning of June 2, 2009, after an email exchange and a phone call with Wernerfelt, Nguyen went to a campus roof and jumped; summary judgment for defendants was granted in Superior Court and affirmed by the SJC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether university owed affirmative duty to prevent student suicide | MIT owed a duty of reasonable care to take steps to prevent Nguyen’s suicide given interactions and awareness of his depression/attempts | No special relationship arose here; generally no duty to prevent another’s suicide absent special relationship or actual knowledge of plan/attempt while enrolled | University may owe limited duty when it has actual knowledge of a student’s suicide attempt while enrolled or of stated plans to commit suicide; here no such duty was triggered as matter of law |
| Whether MIT personnel created a special relationship with Nguyen | Randall/others established a protective relationship by intervening and coordinating care in 2007 | Interactions were limited, Nguyen refused services, sought outside care, and revoked release of information | No special relationship existed between Nguyen and defendants (Randall had no actionable knowledge of imminent risk; faculty lacked knowledge of plans) |
| Voluntary-assumption-of-duty theory | MIT’s mental-health services and contacts created an assumed duty and reliance | Nguyen rejected MIT services and relied on outside clinicians; MIT’s brief contacts did not increase risk | No liability under voluntary-assumption theory because services were declined and no detrimental reliance shown |
| Other claims: punitive damages, conscious pain and suffering, breach of contract, amendment to add chancellor, workers’ comp exclusivity | Plaintiff sought punitive/emotional damages, contract damages, amendment to add Chancellor Clay, and argued Nguyen was not MIT employee | Defendants argued no negligence, thus no punitive/emotional/contract relief; amendment futile; employee status disputed | Claims for punitive, emotional, breach of contract, and amendment were rejected; denial of summary judgment on workers’ compensation (employment status) was proper due to material factual disputes |
Key Cases Cited
- Slaven v. Salem, 386 Mass. 885 (recognizes duty in custodial contexts and where defendant knows or should know of suicide risk)
- Mullins v. Pine Manor Coll., 389 Mass. 47 (discusses modern university-student relationship and expectations of protection)
- Irwin v. Ware, 392 Mass. 745 (factors for delineating tort duties such as foreseeability and reliance)
- Cremins v. Clancy, 415 Mass. 289 (general rule that there is no duty to rescue absent special circumstances)
- Jupin v. Kask, 447 Mass. 141 (elements of negligence claim)
- Stepakoff v. Kantar, 393 Mass. 836 (medical professional standard of care discussion)