Williams v. Peninsula Regional Medical Center
213 Md. App. 644
Md. Ct. Spec. App.2013Background
- On April 20, 2009, Charles Williams, Jr. was brought to Peninsula Regional Medical Center (PRMC) for psychiatric evaluation after his mother reported suicidal ideation, hallucinations, and bizarre behavior.
- Dr. Michael P. Murphy and nursing assistant George Stroop evaluated Williams; he was alert, cooperative, admitted hallucinations and suicidal thoughts, but refused inpatient care.
- The providers diagnosed insomnia/fatigue and bizarre behavior, prescribed Ambien, advised removal of firearms and outpatient follow-up, and decided not to involuntarily admit Williams.
- Later that day Williams broke into a home, threatened officers with a knife, charged them, and was shot and killed by police.
- Williams’s family filed a wrongful death/negligence suit against the providers; the circuit court dismissed under Maryland’s involuntary admission immunity statute (H-G § 10-618/CJP § 5-623) for actions taken in good faith and with reasonable grounds.
- The Maryland Court of Special Appeals affirmed, holding the immunity covers evaluations that result in a decision not to involuntarily admit and that the complaint alleged only ordinary negligence, not facts showing lack of good faith or unreasonable grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether H-G § 10-618 immunity applies to evaluations that result in non‑admission | Williams’s family: immunity applies only when an involuntary admission actually occurs | Providers: immunity covers actions taken in compliance with Part III, including evaluations that conclude not to admit | Court: immunity covers evaluations whether or not they result in admission |
| Whether the complaint sufficiently alleged facts to overcome the immunity (i.e., acted not in good faith or without reasonable grounds) | Family: "good faith/reasonable grounds" is effectively negligence; expert reports alleging breach of standard of care suffice | Providers: statute protects more than mere negligence; plaintiffs must plead facts showing lack of good faith or absence of reasonable grounds | Court: complaint alleged only negligence; dismissal affirmed because plaintiffs did not plead facts to rebut statutory immunity |
Key Cases Cited
- S.P. v. City of Takoma Park, 134 F.3d 260 (4th Cir. 1998) (discusses discretion afforded private providers under Maryland involuntary commitment scheme)
- Farwell v. Un, 902 F.2d 282 (4th Cir. 1990) (involuntary commitment statutes limit physician duty and protect patients' liberty and dignity)
- Anderson v. Dep’t of Health and Mental Hygiene, 310 Md. 217 (1987) (civil commitment implicates significant liberty interests and due process)
- Ziemba v. Riverview Med. Ctr., 645 A.2d 1276 (N.J. Super. Ct. App. Div. 1994) (statutory immunity protects discretionary commitment decisions and the evaluation process)