Smith v. Department of Mental Health, State

8 Ct. Cl. 202
CourtWest Virginia Court of Claims
DecidedFebruary 15, 1971
DocketNo. D-300; No. D-301
StatusPublished

This text of 8 Ct. Cl. 202 (Smith v. Department of Mental Health, State) is published on Counsel Stack Legal Research, covering West Virginia Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Department of Mental Health, State, 8 Ct. Cl. 202 (W. Va. Super. Ct. 1971).

Opinion

PETROPLUS, JUDGE:

The above captioned cases were consolidated and heard together on October 13, 1970. The material facts of the first case, Claim No. D-300, are found to be substantially as follows:

[203]*203Claimant, Cecil Smith, Jr., while legally committed and confined in Weston State Hospital, an Agency of the State of West Virginia under the supervision and control of the Respondent, Department of Mental Health of the State of West Virginia, was attacked and beaten by another inmate of Weston State Hospital in a brief fight on July 4,1967. The other inmate, Jack Biggs, who had been confined periodically in the Penitentiary at Moundsville for various offenses, including homicide, was transferred from time to time to the Mental Hospital at Weston for psychiatric evaluation, treatment and restraint. He had an erratic history of mental disturbances and delusions. On July 29, 1965, about two- years before the assault in question, a written psychiatric evaluation disclosed him to be a man of mental confusion, suffering from emotional and mental disturbances, anti-social reactions with delusions of all kinds. In his history, we find that he stabbed a Penitentiary Guard for interfering with his reading of the Bible, an attempt to commit suicide by jumping off the wall of a building and delusions of persecution. A later report dated August 22, 1966, found him in active psychosis, harboring feelings that outside people were against him, impaired judgment 'but physically in good condition. The latter report shows an improvement in his conduct. Further reports in the file indicate behavioral problems and anti-social conduct up to the time of the assault but no particular acts of violence during that time. The technical diagnosis of Biggs’ condition was “schizophrenic reaction, paranoid chronic undifferentiated type”. Biggs was discharged from the Hospital on August 11, 1967, and returned on April 13, 1970, after being re-arrested for breaking into and vandalizing a Church and his conduct thereafter has been very aggressive and hostile. We have gone into considerable detail on his; history as it has a bearing on whether the Respondent’s Agents1, Officers and Employees have failed to use reasonable care to safeguard the Claimant from harm by another inmate in the-Institution.

At the hearing, the evidence developed that the attack on. the Claimant was unprovoked and resulted in a serious compound fracture of the Claimant’s arm in the same place where-it had previously been fractured in a baseball game and secured in place with screws. An 80% impairment of the normal use of the arm has resulted from the re-fracture.

[204]*204Respondent is charged with negligence in supervising and safeguarding the Claimant while he was confined in Weston.

The second case, Claim No. D-301, has been filed against the Department of Public Institutions of the State of West Virginia and alleges that the Claimant did not receive proper medical care from the State for his injuries. The Claimant was x-rayed at Weston, given first aid. and transferred to Fairmont Emergency Hospital shortly after the attack where his injury was diagnosed as a re-fracture of the distal humerus of the right arm. Claimant remained there with his arm in a cast until September, 1967, at which time he was returned to Weston State Hospital. The fracture was reduced by manual manipulation and Claimant’s arm remained in a cast on a closed reduction until September, 1967, when the cast was removed, revealing excessive swelling in a crooked arm, and with much pain and suffering. The arm was disfigured and could not be used functionally. A further examination at Weston State Hospital disclosed that there was considerable overriding of the fragments at the fracture joint and that an open re-reduction would have to be performed on the arm through the medium of surgical incision. The bone had to be rebroken 'and reset to correct this condition and on September 23, 1967, Claimant was returned to Fairmont Emergency Hospital where Dr. Salazar performed an operation to bring the bones into alignment. Claimant’s arm was again placed in a cast until on or about December 1, 1967, and now appears to be in proper alignment. He has less than 20% of the normal use of his arm. The condition is not improving and another operation may be needed. The second claim is based on the failure of Respondent’s Agents and Employees to properly diagnose the fracture and the failure to use reasonable care in reducing the fracture, in accordance with the usual and ordinary standards of the medical profession. Damages in the 'amount of $10,500.00 are sought in each of the above cases.

At the hearing, by agreement of counsel, the National Bank of Commerce, Committee for Cecil Smith, Jr., Claimant, was substituted as the complaining party. Inasmuch as the Claimant was under a mental disability, the two-year Statute of Limitations has no application to the cause of action in each case.

[205]*205After careful consideration of the evidence and the duties and obligations of the Department of Mental Health to protect an ¡incompetent person in its care and custody from a violent ¡attack by other inmates in the Institution, it is the opinion of the Court that under the circumstances of this case there is no showing of negligence on the part of the Hospital. In a Mental Institution where many persons are confined under various kinds of insanity, it must toe necessarily assumed that deranged persons will deviate from normal conduct and will engage in irrational acts and fights. Biggs became incensed at Claimant for refusing to “hang it up” (meaning commit suicide) after Claimant had promised to do so. They had formerly been buddies for some months. This, of course, does not relieve the Institution from exercising ordinary and reasonable care to protect its inmates from the violent and unpredictable conduct of other disturbed persons. The medical history of Jack Biggs does reveal an incompetent person prone to violence, motivated towards suicide and with delusions of persecution. It appears to us that the Hospital was without notice of the imminent danger to the Claimant and should not be held liable for his mistreatment toy another patient unless the Hospital failed to protect the Claimant from an obvious and certain danger. We find no evidence in the Record that the administrative conduct of the Hospital was such as to expose the Claimant unnecessarily to injuries through failure to use reasonable care under the circumstances. Three to six guards were on duty in this area of the Hospital where maximum security was provided because of the toad histories of the inmates confined in this particular wing. A constant surveillance to restrain insane, delirious or disabled patients is physically and economically impossible. In the opinion of the Court, the Hospital should only toe held liable if the patient is unreasonably exposed to hazards other than those which would be considered ordinary and normal risks in any Mental Institution.

The Court is of the opinion to deny any award to the Claimant or impose any liability on ¡the Hospital for failure to exercise reasonable care in guarding the Claimant, its patient, from violence inflicted by others. To hold otherwise, would require the Hospital to place each mental patient in solitary seclusion to alleviate quarrels, assaults and attacks. A Hospital [206]*206must operate within the budget furnished by the Legislature and its personnel is necessarily limited for employment of doctors, nurses, guards and other employees.

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8 Ct. Cl. 202, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-department-of-mental-health-state-wvctcl-1971.