Court Holds That There Can Be a Limited Duty for a University to Attempt to Prevent a Student’s Suicide in Massachusetts

Suicide claims tens of thousands of lives annually in the United States alone, including a disproportionate number of those in their teens and twenties. Given that there are more than 10 times the number of emergency department visits for self-inflicted injuries as there are completed suicides, there can sometimes be a window of opportunity to prevent a successful suicide.

If an individual or entity that owes a duty of care to a suicidal person does not act in a way that is reasonably prudent under the circumstances, a Cape Cod wrongful death action may be appropriate.

Facts of the Case

In a recent case, the plaintiff was the administrator of the estate of a young man who committed suicide while attending a prestigious graduate school. At the time of his death, the deceased was 25 years old and lived off campus. The plaintiff asserted a claim for wrongful death against the university, two professors, and an assistant dean. The trial court granted summary judgment to the defendants, finding that they had no duty to prevent the young man’s suicide. The Massachusetts Supreme Judicial Court granted the plaintiff’s application for direct appellate review.

The Court’s Decision on Appeal

The supreme court affirmed the dismissal of the plaintiff’s wrongful death lawsuit on summary judgment. On appeal, the plaintiff argued that the defendants owed the deceased a duty of reasonable care and that this duty was breached. The court began by observing that there is not usually any duty imposed upon a “stranger” to go to the aid of someone in danger, even if that person could lose their life if no intervention is made.

In the case of “special” relationships, such as the custodial relationship between a jail and an inmate or a hospital and a patient, an affirmative duty of rescue can sometimes be imposed. This includes the duty to prevent suicide. With respect to the relationship between a university and a student, the court held that a limited duty may exist in some situations but went on to find no such duty was created in the case at bar.

In so holding, the court noted that the deceased never communicated to university employees – either by words or by actions – that he had any intention of committing suicide. Although he had a history of treatment for mental illness, he repeatedly made it clear that he wished to keep his mental health care issues separate from his problems concerning academic performance.

Talk to a Knowledgeable Cape Cod Wrongful Death Lawyer

Cape Cod wrongful death claims can arise in a number of contexts – car or truck accidents, premises liability or slip and fall cases, product defects, and medical malpractice, to name a few. If your family has recently suffered the tragic and preventable loss of a loved one, the Law Offices of John C. Manoog, III, can help you explore the possibility of legal action against the responsible person, business, or governmental entity. For an appointment in our Hyannis or Plymouth offices, call us at 888-262-6664.

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