SALISBURY — The state’s highest court this week ruled health care providers at PRMC could not be held liable for not admitting a man with mental problems, including suicidal thoughts and hallucinations, who was later shot and killed the same day by police in an apparent “suicide by cop” case.
In April 2009, family members brought Charles Williams, Jr. to PRMC for evaluation over concerns of his mental state after he allegedly was having suicidal thoughts and visual and auditory hallucinations. According to court documents, Williams also believed he was under a curse and exhibited other obsessive and unusual behavior. Williams was examined and evaluated at PRMC during which he was alert, verbal and cooperative in discussing his symptoms.
Although he was lucid and cooperative, Williams told healthcare providers he was experiencing hallucinations and had been considering suicide. Williams also told his examiners he believed his ex-girlfriend had put a curse on him and that he experienced blindness when he looked at a text message sent from her while in the emergency room.
However, Williams refused to discuss the possibility of impatient care and healthcare providers noted in their reports he “appeared to be minimizing any problems going on with him,” according to court records. After evaluating Williams, PRMC healthcare providers decided not to involuntarily admit him. Instead, he was diagnosed with insomnia, fatigue and bizarre behavior and was prescribed Ambien.
In addition, his mother was advised to remove any firearms from the residence and follow up the next day with the Lower Shore Clinic and return to the hospital immediately if the symptoms became worse. According to court documents, Williams was also told “to return here immediately if you feel you are going to harm yourself or anyone else.”
After leaving PRMC, Williams’ mother filled his prescription and they went to a nearby restaurant. Williams and family members later left the restaurant, but Williams asked his mother to pull over and he jumped out of the vehicle. Salisbury Police saw Williams later in the day and noted he was acting strange, but was doing nothing that would cause them to detain him.
Shortly after midnight, Williams broke into a house and the resident called 911. When police arrived, Williams was in the front yard wielding a knife. He allegedly said to the officers, “shoot me, [expletive deleted] shoot me, somebody’s going to die tonight.” He then held the knife to his throat and allegedly said, “I want you to shoot me. I want to die.”
Police told Williams to drop the knife and surrender, but he refused and charged at the officers. The officers shot Williams, but he persisted in the attack. Ultimately, the officers shot Williams 15 times and he died from the gunshot wounds.
Williams’ family later filed suit in Wicomico County Circuit Court alleging PRMC and the healthcare providers that treated Williams were negligent in not involuntarily admitting him. Citing a statute providing immunity for healthcare providers in involuntary admission cases, and also pointing out the family members had not been successful in alleging any facts to overcome the immunity statute, a Wicomico County judge granted the defendants’ motion to dismiss the case.
Williams’ family then filed an appeal in the Maryland Court of Special Appeals. The higher court later concurred with the Wicomico County Circuit Court judge’s interpretation of the statute and affirmed the dismissal. Williams’ family then appealed the case to the Court of Appeals, which this week issued its opinion upholding the rulings of the lower courts.
Essentially, the Court of Appeals opined the case boiled down to a debate over involuntary admission of patients. Health care providers at PRMC could have admitted Williams against his will and run the risk of violating his civil liberties, or as they ultimately did, release him to the care of family members.
“If the General Assembly’s intention was to protect individuals from undue deprivation of liberty, it would make little sense to give health care providers an incentive to err on the side of involuntary admittance in order to receive statutory immunity and avoid liability,” the opinion reads. “Instead, the statutory scheme protects the discretion of health care providers tasked with deciding whether to involuntarily admit an individual.”
While acknowledging the tragic nature of the case, the Court of Appeals opined the health care providers did not err in their decision not to involuntarily admit Williams.
“Understanding the deep concern for patient rights and stringent requirements for involuntary admittance, it would lead to an absurd result if we were to interpret the immunity provision to only apply when someone is actually admitted,” the opinion reads. “In one breath, the statute would discourage admitting individuals before a careful evaluation, but in the next breath provide immunity only when the decision is to admit. Out of fear of liability, mental health professionals might err on the side of admittance instead of properly exercising their discretion and following the stringent requirements before taking away someone’s liberty.”