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plaintiffdefendantnegligence
trialpleawillappellantappellee

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Emerich v. Philadelphia Center for Human Development, Inc., 554 Pa. 209, 720 A.2d 1032

Facts

Teresa Hausler and Gad Joseph were in a relationship and both received mental health treatment at the Philadelphia Center for Human Development. Joseph had a history of violent behavior and had threatened to kill Hausler. On June 27, 1991, Joseph called his counselor, Mr. Scuderi, and expressed his intention to kill Hausler. Despite this, after a therapy session, Joseph was allowed to leave the center based on his assurances that he would not harm her. Hausler, disregarding a warning from Scuderi not to go to Joseph's apartment, was subsequently murdered by him.

The factual allegations raised in Appellant's complaint, which we must accept as true, are as follows. Ms. Hausler and Joseph, girlfriend and boyfriend, were cohabitating in Philadelphia. For a substantial period of time, both Ms. Hausler and Joseph had been receiving mental health treatment at Appellee Philadelphia Center for Human Development (the 'Center' or 'PCHD'), which is owned and operated by Appellees Albert Einstein Healthcare Foundation and Albert Einstein Medical Center.

Issue

Whether a mental health professional has a duty to warn a third party of a patient's threat to harm that third party, and if so, the scope of that duty.

We granted allocatur limited to the issues of one, whether a mental health professional has a duty to warn a third party of a patient's threat to harm the third party; two, if there is a duty to warn, the scope thereof; and finally, whether in this case a judgment on the pleadings was proper.

Rule

A mental health professional has a duty to warn a third party of a patient's specific and immediate threat of serious bodily injury when such a threat has been communicated regarding a specifically identified or readily identifiable victim.

A mental health care professional, under certain limited circumstances, owes a duty to warn a third party of threats of harm against that third party.

Analysis

The court applied the rule by determining that Joseph's threats to Hausler constituted a specific and immediate danger that warranted a warning. The court found that Mr. Scuderi's warning to Hausler not to go to Joseph's apartment fulfilled the duty to warn, as it was a direct response to the communicated threat. The court emphasized that the duty to warn arises only in limited circumstances where a clear threat is made against a specific individual.

The court found that in this case, judgment on the pleadings was proper, and thus, we affirm the decision of the learned Superior Court, albeit, for different reasons.

Conclusion

The Supreme Court affirmed the lower court's judgment, concluding that the mental health professional's warning to the victim satisfied the duty to warn, and thus, the defendants were not liable for negligence.

Thus, we will not require a mental health professional to be liable for a patient's violent behavior because he fails to predict such behavior accurately.

Who won?

The defendants prevailed in the case because the court found that they had fulfilled their duty to warn the victim, and the plaintiff could not establish a cause of action for negligence.

The trial court granted judgment on the pleadings in favor of Appellees finding, inter alia, that the duty of a mental health professional to warn a third party had not yet been adopted in Pennsylvania, but that even if such a legal duty existed, Mr. Scuderi's personal warning discharged that duty.

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