Littleton v. Good Samaritan Hospital & Health Center

Our threshold issue requires us to determine under what circumstances a psychiatrist can be held liable for the violent acts of a *92voluntarily hospitalized patient following the patient’s release from the hospital.

To maintain a wrongful death action on a theory of negligence, a plaintiff must show (1) the existence of a duty owing to plaintiff’s decedent, (2) a breach of that duty, and (3) proximate causation between the breach of duty and the death. Bennison v. Stillpass Transit Co. (1966), 5 Ohio St. 2d 122, 34 O.O. 2d 254, 214 N.E. 2d 213, paragraph one of the syllabus. The same three…