Unglo v. Zubik, 29 A.3d 810

Appellant Administrator sues Diocese for wrongful death of Michael R. Unglo, alleging long-term sexual abuse by a priest and subsequent medical treatment funded by the Diocese.
Decedent suffered abuse from 1982–1985; later achieved academic and professional success, but suffered emotional distress and suicide attempts beginning in 2008.
Diocese initially funded counseling and treatment after the 2008 suicide attempt and committed to address the wrong done to Decedent.
Diocese gradually limited and then terminated future funding for treatment, culminating in a final offer of $75,000 in March 2010, with no further services to be provided.
Psychotherapist advised continued treatment in April 2010; Diocese allegedly knew discontinuation would terminate care and harm Decedent, potentially causing distress leading to suicide.
Decedent committed suicide on May 4, 2010, while still receiving some treatment but after the Diocese signaled it would discontinue funding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint states a § 823 Restatement claim.	Unglo contends § 823 supports negligent maintenance of care.	Diocese argues no duty or causal link under § 823 exists.	No viable § 823 negligence claim; demurrer proper.
Whether § 323 Comment c supports liability for termination of services.	Appellant argues the Diocese’s termination caused distress leading to suicide.	Diocese cites Comment c permitting termination absent worsened position; no liability.	Comment c does not impose liability here; termination was allowed as Decedent was not worsened by prior aid.

Feld v. Merriam, 506 Pa. 383 (Pa. 1984) (restatement-adoption and duty concepts in Pennsylvania tort law)
Cooper v. Frankford Health Care System, Inc., 960 A.2d 134 (Pa.Super.2008) (Restatement §323 applicability in Pennsylvania context)
Filter v. McCabe, 733 A.2d 1274 (Pa.Super.1999) (application of §323 and related duties)