A New York appeals court recently decided the case of a teenager who committed suicide on the night he was discharged from the emergency room. The court acknowledged the tragic circumstances of his death but ultimately affirmed the trial court’s decision for the defendants. This case shows the unique evidentiary considerations facing plaintiffs when attempting to show New York psychiatry malpractice, which is not as observable as other forms of malpractice.
The patient was admitted to the Cayuga Medical Center emergency room after his school nurse observed that he had mood swings and suspected that he might have used illegal drugs. The patient was previously treated at the same hospital, a year before, for suicidal ideation, self harm, and rapid mood swings, and the hospital’s psychiatrist diagnosed the patient with a mood disorder brought on by substance abuse. The psychiatrist did not examine the patient personally when he was admitted for the second time. Instead, the psychiatrist referred to his notes from the patient’s earlier visit, as well as a mental health evaluation conducted by the emergency room nurse, and consulted the patient’s outpatient therapist, who said that although the patient was abusing drugs, he had not expressed suicidal tendencies. The patient was released from the hospital. Later that same night, after returning home, he committed suicide.
The patient’s parents sued the psychiatrist, Cayuga Medical Center, and the management company, Cayuga Emergency Physicians LLP, alleging medical malpractice, among other causes of action. The trial court granted summary judgment in favor of the defendants, and the plaintiffs appealed the decision. The court of appeals affirmed the trial court’s decision because the plaintiffs could not show that the physicians breached the appropriate standard of care. Instead, the court found that the plaintiffs were merely alleging that the doctors erred in their professional judgment.