Kowalski v. St. Francis Hospital & Health Centers

OPINION OF THE COURT

Smith, J.

We hold that, on the facts of this case, a hospital and an emergency room doctor did not owe an intoxicated patient a duty to prevent him from leaving the hospital.

*484I

Plaintiff was brought by a friend to the emergency room of defendant St. Francis Hospital and Health Centers, seeking admission to St. Francis’s detoxification facility, known as “Turning Point.” This was at least plaintiff’s second visit to St. Francis; he had been admitted there in the previous month with suicidal thoughts and had been placed on a “one-to-one watch.” On that occasion, he improved…