In a major ruling that impacts mental health care and medical malpractice law in Pennsylvania, the Pennsylvania Supreme Court has held that hospitals can be held liable for rejecting voluntary mental health patients—even if intake paperwork is not completed.
Key Case: Wise v. Geisinger and Alley Medical Centers
The court’s decision stems from the tragic case of Westley Wise, who sought inpatient mental health treatment after experiencing suicidal and violent thoughts. Despite requesting help, Wise was discharged from Geisinger Medical Center and Alley Medical Center without being admitted. Days later, he fatally stabbed his girlfriend, Jessica Frederick.
Her family filed a wrongful death lawsuit, alleging gross negligence under Pennsylvania’s Mental Health Procedures Act (MHPA). While the healthcare providers argued that no formal application for treatment was completed, the court ruled 6-1 that a verbal request is enough to trigger liability under the MHPA.
Frederick’s estate is represented by Michael D. Shaffer of Shaffer & Gaier LLC.
Court’s Interpretation of the Mental Health Procedures Act
Chief Justice Debra Todd, writing for the majority, clarified that Section 114(a) of the MHPA imposes liability for “willful misconduct or gross negligence” when a facility denies treatment to someone voluntarily seeking admission. The court also cited Section 103, which allows liability even when a patient verbally requests treatment without completing written forms.
In dissent, Justice David Wecht argued that the MHPA requires completed paperwork and that the court’s interpretation bypasses procedural safeguards established by the legislature.
What This Means for Medical Malpractice and Mental Health Law
This decision establishes that healthcare providers must take verbal mental health admissions seriously. Refusing treatment to someone experiencing a mental health crisis—especially when they ask for inpatient care—could now expose providers to legal action for gross negligence or medical malpractice.
How Anzalone & Doyle Trial Lawyers Can Help
At Anzalone & Doyle Trial Lawyers, we represent families and individuals harmed by medical negligence—especially when hospitals fail to act during a mental health crisis. Our experienced team of personal injury attorneys understand the complex legal landscape of Pennsylvania’s medical malpractice laws and fight for justice in wrongful death and gross negligence cases.
If you or a loved one has been harmed through no fault of your own due to medical malpractice or the negligent refusal of mental health treatment, you may be entitled to compensation. The team of attorneys here at Anzalone & Doyle Trial Lawyers has the knowledge and experience to help families protect their rights and hold negligent providers accountable. Contact Anzalone & Doyle Trial Lawyers today for a free consultation regarding your potential Medical Malpractice or other Personal Injury Negligence case.
