In Gineene Williams, et al. v. Peninsula Regional Medical Center, et al.,
2014 Md. LEXIS 781 (2014), the Court of Appeals of Maryland held that that the involuntary admission immunity
statute codified at the Health General Article of the Maryland Annotated Code, Section
10-618 applied to health care providers who evaluated an individual and decided
in good faith to involuntarily admit - or not admit - that individual.
Section
10-618 reads in relevant part that "[a] person who applies for
involuntary admission of an individual shall have the immunity from
liability described under § 5-623(b) of the Courts and Judicial
Proceedings Article," which states that "[a] person who in good faith and with reasonable
grounds applies for involuntary admission of an individual is not civilly or
criminally liable for making the application." The Court’s ruling dissolved any ambiguity in the statute
in relation to its application of liability to situations in which a healthcare
provider declines to apply for involuntary admission of an individual.
On
April 20, 2009, Gineene Williams brought her son, Charles Williams, Jr.
(“Williams”), to Peninsula Regional Medical Center (“PRMC”) for evaluation
relating to suicidal ideation
and auditory and visual hallucinations. Upon completing the examination,
the health care providers elected not to admit Williams, instead
discharging him to the care of his mother and advising her to remove
any firearms from the home. Later that evening, Williams escaped from his
mother's care, wandered the streets, broke into a local residence, and engaged
with law enforcement, resulting in his death. His family sued PRMC for wrongful
death.
PRMC
filed a Motion to Dismiss for failure to state a claim upon which relief may be
granted, asserting statutory immunity under section 10-618. Plaintiffs asserted the statute only
applied to situations in which a healthcare provider ultimately sought
admission of a patient, and thus did not apply to PRMC in Williams’ case. The
trial court, Court of Special Appeals, and the Court of Appeals of Maryland all
disagreed.
In reaching its opinion upholding both the lower
courts, the Court considered the language of the text, the legislature's
intent, and general public policy. The Court reasoned that:
"[i]f
the General Assembly’s intention was to protect individuals from
undue deprivation of liberty, it would make little sense to give health
care providers an incentive to err on the side of involuntary admittance
in order to receive statutory immunity and avoid liability. Instead, the
statutory scheme protects the discretion of health care providers tasked
with deciding whether to involuntarily admit an individual."
Williams, 2014 Md. LEXIS at *19.
By applying the statute in the
reverse, the Court of Appeals of Maryland resolved the ambiguous statutory
language and removed the fear of a lawsuit out of the decision making process
for the analysis of involuntary admissions.
