Volk v. DeMeerleer

¶1 Jan DeMeerleer murdered Rebecca Schiering and her nine-year-old son Philip and attempted to murder Schiering’s older son, Brian Winkler. After the attack, DeMeerleer committed suicide. DeMeerleer had been an outpatient of psychiatrist Dr. Howard Ashby for nine years leading up to the attack, during which time he expressed suicidal and homicidal ideations but never named Schiering or her children as potential victims. We must decide whether Ashby, a mental health professional, owed DeMeerleer’s victims a duty of care based on his relationship with DeMeerleer. We hold that Ashby and…