Hamman v. County of Maricopa

Robert and Alice Hamman (plaintiffs) sued the County of Maricopa (defendant) after Mr. Hamman was severely beaten and injured by his stepson, John Carter. Carter lived with the Hammans and had a history of schizophrenia, psychosis, and drug abuse. Two days before the attack, the Hammans had taken Carter to the county’s emergency psychiatric center, requesting that Carter be admitted after exhibiting strange and violent behavior. Carter had been hospitalized at the center before. Then, Carter was noncompliant with his prescription and required seclusion and restraint most of the time. When Carter was taken to the center before the attack, the Hammans relayed concerns about Carter’s behavior to Dr. Suguitan. However, Dr. Suguitan examined Carter for five minutes and, without reviewing Carter’s medical records, told the Hammans that Carter was harmless and released Carter to the Hammans with a prescription. Dr. Suguitan did not prescribe outpatient care or give instructions for dealing with Carter’s deterioration or noncompliance. Subsequently, Carter attacked Mr. Hamman. Mr. Hamman had a heart attack during the attack and suffered severe brain damage. In their lawsuit, the Hammans alleged that Dr. Suguitan’s malpractice and negligent treatment, along with the county’s negligent training and supervision of its personnel, were the cause of Mr. Hamman’s injuries. A trial court granted summary judgment for the county because Carter never verbalized specific threats against the Hammans. The Hammans appealed, and a court of appeals divided their claims into two theories. The first theory related to Dr. Suguitan’s duty to the Hammans, and the second related to the Hamman’s reasonable reliance on Dr. Suguitan’s opinion that Carter was harmless. The court of appeals affirmed that Dr. Suguitan owed no duty to the Hammans but found that the couple had reasonably relied on Dr. Suguitan’s opinion. The Hammans appealed.