Huntley v. State
| Citation | 62 N.Y.2d 134,464 N.E.2d 467,476 N.Y.S.2d 99 |
| Parties | , 464 N.E.2d 467 Helen HUNTLEY, Respondent, v. STATE of New York, Appellant. |
| Decision Date | 15 May 1984 |
| Court | New York Court of Appeals Court of Appeals |
Where a psychiatric hospital patient with a history of instability communicated her specific suicide plan involving an off-premises location to a hospital staff member, failure to transmit such information to the staff psychiatrist (who controlled the patient's privileges to leave hospital premises) constituted a breach of duty and rendered the hospital liable for negligence. CPLR 4010, which limits the application of the collateral source rule in medical malpractice actions, has no application to the hospital's liability for negligence.
At issue on this appeal is the liability of appellant, the State of New York, for injuries sustained by respondent, Helen C. Huntley, a patient at the State's Hutchings Psychiatric Center, when she left the hospital premises, unsupervised, and jumped from the roof of a nearby parking garage. The Court of Claims determination in respondent's favor, finding the evidence sufficient to establish appellant's negligence, was unanimously affirmed by the Appellate Division, 96 A.D.2d 724, 465 N.Y.S.2d 87.
Given the correct application of legal standards and affirmed findings of fact, our scope of review is limited. Where such findings are supported by evidence in the record, they are conclusive in this court. (Humphrey v. State of New York, 60 N.Y.2d 742, 469 N.Y.S.2d 661, 457 N.E.2d 767.) Here, there was ample evidence to support the finding that appellant on the day of the accident failed in its duty to supervise its patient adequately, leading her to her injury (see Martindale v. State of New York, 269 N.Y. 554, 199 N.E. 667; Horton v. Niagara Falls Mem. Med. Center, 51 A.D.2d 152, 380 N.Y.S.2d 116 ). Apart from respondent's history of mental instability and her depression, deterioration and unusual behavior shortly before the accident, there was evidence that, one day prior to her jump from the garage roof, respondent had communicated this specific suicide plan to a hospital staff member, and that this information was not transmitted to the staff psychiatrist so that he could consider what impact--if any--it should have on respondent's privileges to...
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