Estates of Morgan v. Fairfield Family Counseling Center
Supreme Court of Ohio
673 N.E.2d 1311 (1997)
Relevant factsFree
After Fairfield's (defendant's) staff took outpatient Morgan off his schizophrenia medication, he began experiencing violent outbursts and put a deposit on a gun, and his mother specifically informed Fairfield of his deteriorating condition and requested involuntary hospitalization; Fairfield evaluated Morgan but chose not to hospitalize him, and he subsequently killed both parents, prompting their estates (plaintiffs) to sue for breach of a duty to control his violent acts, with the trial court granting Fairfield summary judgment.
IssueFree
Whether a psychiatrist has a duty to protect a third party from the violent propensities of the psychiatrist's patient in an outpatient setting.