Schrempf v. State, 66 N.Y.2d 289 (1985)

The State is not liable for injuries inflicted by a released mental patient where the decision to release or maintain the patient on outpatient status was based on a reasoned professional judgment, even if that judgment ultimately proves to be incorrect.

Summary

The husband of the claimant was fatally stabbed by Joseph Evans, a mental patient on outpatient status. The claimant sued the State, alleging negligence in failing to commit Evans prior to the assault. The Court of Claims found the State liable, and the Appellate Division affirmed. The New York Court of Appeals reversed, holding that the psychiatrist’s decision to maintain Evans on outpatient status was a matter of professional judgment and, therefore, not a basis for liability. The court emphasized that psychiatric decisions involve calculated risks and that disagreement among experts does not automatically establish negligence. The treating psychiatrist considered that Evans was calm and cooperative and that aggressive intervention could be counterproductive.

Facts

Joseph Evans, a 27-year-old with a history of mental illness, was an outpatient at Hutchings Psychiatric Institute. He had been admitted six times, often following violent incidents. His diagnoses included manic depression and paranoid schizophrenia. Evans’ condition generally improved with medication and therapy, but he was an unreliable outpatient, often missing appointments and neglecting his medication. In September 1981, Evans voluntarily returned to Hutchings, where a psychiatrist determined he did not pose an immediate risk and placed him on outpatient status. In November, he began a vocational rehabilitation program. He did not regularly take his prescribed medication, which the psychiatrist addressed by reducing the dosage and rescheduling when he complained that the drugs made him drowsy at work.

Procedural History

The claimant sued the State in the Court of Claims for wrongful death, alleging negligent care and treatment of Evans. The Court of Claims found the State negligent for admitting Evans to outpatient care in September 1981. The Appellate Division affirmed. The State appealed to the New York Court of Appeals.

Issue(s)

Whether the State can be held liable for negligence in the care and treatment of a mental patient who, while on outpatient status, injures a third party when the decisions regarding the patient’s care were based on the exercise of professional medical judgment.

Holding

No, because the decision to place Evans on outpatient status and to continue that status despite his non-compliance with medication was based on a reasoned professional judgment, and the State is not liable for mere errors in such judgment.

Court’s Reasoning

The Court of Appeals acknowledged the State’s duty to provide reasonable care to mental patients and to protect the public from potentially dangerous individuals. The court differentiated between governmental functions (e.g., police protection, for which a special relationship is required for liability) and proprietary functions (e.g., medical care, for which the State is held to the same standard of care as private actors). The court emphasized that psychiatric care involves a balancing of interests: the patient’s rehabilitation and the public’s safety. Because psychiatry is not an exact science, decisions regarding treatment involve calculated risks and often generate disagreement among experts. The court stated that “the modern and more humane policy of the medical profession and the law contemplates returning the mental patient to society, if he does not pose an immediate risk of harm to himself or others.”

The court found that the psychiatrist’s decision to maintain Evans on outpatient status, despite his erratic medication compliance, was a matter of professional judgment. The psychiatrist had considered Evans’ history, his cooperative behavior, and the potential disruption that involuntary commitment could cause. The court noted that even the claimant’s experts did not agree on the appropriate course of action. The court concluded that, while the psychiatrist’s judgment proved mistaken in hindsight, it was not negligent because it was based on a reasoned assessment of the available information and the patient’s individual circumstances. As such, “it must be recognized as an exercise of professional judgment for which the State cannot be held responsible.”