Matos v. Geisinger Med. Ctr., 334 A.3d 288 (Pa. 2025)
An individual with an extensive mental health history sought admission to two different mental health facilities for inpatient psychiatric care. However, both facilities denied his request. Shortly after, he killed his girlfriend. The estate of the victim brought suit against the facilities, alleging their denials met the threshold for gross negligence or willful misconduct pursuant to the voluntary-care provisions of the Mental Health Procedures Act (MHPA).
The Pennsylvania Supreme Court found that written consent to voluntary admission into a mental health care facility for inpatient treatment was not a prerequisite to impose liability against health care providers under the MHPA. For involuntary commitment, prior cases, such as Leight, have held that no liability arises unless a formal written application is completed. However, for voluntary admission, the court reasoned that the act of seeking treatment itself is sufficient to trigger the facility’s duty to evaluate and respond reasonably. However, liability attaches only when the denial of voluntary admission constitutes gross negligence.
