Williams v. Peninsula Regional Medical Center
103 A.3d 658
Md.2014Background
- 34-year-old Williams presented with suicidal ideation and hallucinations at PRMC; evaluated and discharged rather than involuntarily admitted; discharge included warnings and no firearms at home.
- Family sued for wrongful death/survivorship alleging negligent evaluation and decision not to admit, among other claims; case dismissed on immunity grounds; Court of Special Appeals affirmed; Maryland Court of Appeals granted certiorari to decide immunity scope.
- Statutes HG §10-618 and CJP §5-623 immunize health care actors involved in involuntary admission—extending to those who evaluate and discharge, not only those who apply for admission.
- Court rejected a narrow readings based on captions or who applies for admission; held immunity attaches when action is in good faith compliance with Part III of the Health-General Article.
- Public policy supports protecting clinicians’ discretionary evaluations to prevent chilling effects and wrongful admissions; immunity extends to providers who evaluate and decide not to admit.
- Conclusion: HG §10-618 and CJP §5-623 immunize health care providers who evaluate and, in good faith, decide not to involuntarily admit an individual; judgment of Court of Special Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does immunity extend to evaluators who discharge | Williams argues immunity applies only to those who apply for involuntary admission | PRMC argues immunity covers evaluators and facilities | Yes, immunity extends to evaluators who discharge in good faith |
| Are captions controlling for statutory interpretation | Captions limit scope to admissions | Captions are catchwords, not controlling | Captions are not controlling; immunity extends beyond admissions |
Key Cases Cited
- Kushell v. Dep’t of Natural Res., 385 Md. 563 (Md. 2005) (statutory construction principles; legislative intent guiding interpretation)
- Lockshin v. Semsker, 412 Md. 257 (Md. 2010) (statutory interpretation; commonsense approach)
- Williams v. Peninsula Reg’l Med. Ctr., 213 Md. App. 644 (Md. App. 2013) (intermediate appellate decision addressing immunity scope)
- Bourgeois v. Live Entm’t, Inc., 430 Md. 14 (Md. 2013) (captions not part of the law; statutory interpretation context)
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (due process rights; civil commitment context)