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Becky S. Moore v. Wyoming Medical Center

825 F. Supp. 1531 (1993)

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Becky S. Moore v. Wyoming Medical Center

United States District Court for the District of Wyoming

825 F. Supp. 1531 (1993)

Facts

Becky Moore (plaintiff), an adult with a history of schizophrenia and bipolar disorder, contacted Wyoming Medical Center (the center) (defendant) requesting medication to help her sleep. When Moore spoke with her therapist, Susan Crabtree, Moore told Crabtree that she needed medication or her body was going to shut down. Crabtree, however, testified that Moore threatened suicide. Due to the threat, Crabtree alerted the center, and police were sent to Moore’s residence. When police arrived, Moore’s coworker was present, and the police determined that the situation was under control. Paramedics arrived later and were instructed by a doctor at the center to bring Moore to the center, even against her will. The paramedics barged into the bathroom, handcuffed Moore, and forcibly dragged her naked into the ambulance. Moore was involuntarily admitted to the center under Wyoming’s amended emergency-detention law. The law allows for emergency detention if there is reasonable cause to believe that an individual is suffering from mental illness, defined as having a disorder that causes the person to be a danger to self or others. Dangerousness is defined as evidencing a substantial probability of harm to self or others based on recent threats or attempts at suicide. Moore argued that the statute’s use of substantial probability instead of imminence was unconstitutional. Moore also argued that the center was negligent in detaining her and was liable for several tort claims. The center argued that Moore’s negligence claim failed because she did not provide expert testimony and that her tort claims were barred by statutory privilege.

Rule of Law

Issue

Holding and Reasoning (Brimmer, J.)

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