Meier v. Ross General Hospital

Kurt Meier was placed in the psychiatric wing of Ross General Hospital (the hospital) (defendant) after he attempted to commit suicide. The hospital had an open-door policy, which allowed patients to live in a home-like setting. Patients were not constrained and were free to move about. The hospital placed Kurt in a second-floor room with an operable window. Kurt committed suicide by jumping out the window. Kurt’s wife (Meier) (plaintiff) sued the hospital and Dr. James Stubblebine (defendant) for wrongful death. At trial, the hospital called witnesses who testified that the hospital’s open-door policy was consistent with accepted industry standards. Meier did not call any expert witnesses but did call Stubblebine. Stubblebine acknowledged that barring Kurt’s window would not have rendered Kurt’s living situation incompatible with the open-door policy. Meier asked the judge to give the following jury instruction: “A plaintiff may properly rely on res ipsa loquitur although he [the decedent] participated in events leading to the accident if the evidence excludes his conduct as the responsible cause.” The hospital argued against that instruction because expert testimony was needed to provide the basis for a res ipsa loquitur instruction. The court declined to give Meier’s requested instruction but gave an instruction with a general explanation of the res ipsa loquitur doctrine. The jury found in the hospital’s and Stubblebine’s favor. Meier appealed.