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Mississippi State Hospital v. Wood8/6/2002
DATE OF TRIAL COURT JUDGMENT: 03/06/2001
NATURE OF THE CASE: CIVIL - MEDICAL MALPRACTICE
TRIAL COURT DISPOSITION: JUDGMENT IN FAVOR OF RENA WOOD AS WRONGFUL DEATH BENEFICIARY FOR HER DAUGHTER, APRIL WOOD, IN THE AMOUNT OF $50,000.
DISPOSITION: AFFIRMED - 8/6/2002
. Rena Wood filed a wrongful death action against the Mississippi State Hospital (MSH), claiming that the hospital violated the standard of care in providing in-patient psychiatric treatment to her nineteen-year old daughter, April Wood, and that this sub-standard care was a proximate contributing cause to April Wood's death by suicide. The case was tried without jury before the Circuit Court of Rankin County and the court entered judgment in favor of Wood, assessing damages at $50,000. MSH has appealed the judgment, claiming that a determination of liability on the part of MSH is against the overwhelming weight of the evidence. Concluding that, under the applicable standard of review, there is evidentiary support for the judgment as entered by the trial court, we affirm the judgment.
I. Facts
. It is unhelpful to repeat in substantial detail the body of evidence presented at trial regarding the unfortunate circumstances that led to young April Wood's hospitalization and ultimate death by suicide while a patient at MSH. It is sufficient to say that there was uncontradicted proof of incidents of substance abuse, multiple unsuccessful suicide attempts, a history of mental depression, and prior hospitalizations to attempt to deal with these problems. Ultimately, April Wood submitted to a voluntary commitment to MSH and was diagnosed with the primary problem of polysubstance drug dependency and a secondary diagnosis of depression. Based on initial evaluations, MSH personnel determined that April Wood's chemical dependency was the more serious problem and began a course of treatment designed primarily to deal with that aspect of her condition. After discovery of the fact that Wood had committed a hospital rule infraction by smoking a marijuana cigarette, she was placed on a form of restriction that involved isolation. At some point during her prescribed period of isolation, she was informed that it was to be extended because of subsequent violations of patient rules. Shortly after that, she was discovered to have caused her own death by hanging.
. Evidence was presented that MSH, in formulating a course of treatment and in evaluating her for possible suicide risk, had relied primarily on the history related by the patient and on her own representations that she was not contemplating such a course. No effort was made to obtain additional medical history from the patient's mother or other family member. Though MSH contended that the involuntary isolation procedure was intended to be therapeutic in effect, the plaintiff presented writings by the patient made before her death indicating that she felt it was a form of punishment, causing her to become more depressed.
. At trial, Wood presented the expert testimony of Dr. Wood Coleman Hiatt, a practicing psychiatrist and former faculty member at the University of Mississippi Medical School, who expressed the view that the course of treatment undertaken by MSH violated the standard of care for a patient presenting the psychological symptoms of April Wood. Dr. Hiatt further offered his expert opinion that this violation of the standard of care was a proximate contributing cause to April Wood's ultimate suicide while a patient at the hospital. In particular, Dr. Hiatt offered the view that MSH personnel had erred in treating her substance abuse problems as the primary focus when she was exhibiting signs of sev
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