Schlotfeldt v. Charter Hospital of Las Vegas

After drinking too much alcohol and taking methamphetamine, Debra Schlotfeldt (plaintiff) went to Charter Hospital (defendant), a hospital that specialized in drug and alcohol addiction. Charter conducted a psychiatric exam of Schlotfeldt, during which Schlotfeldt discussed problems with gambling, depression, and thoughts of suicide. Schlotfeldt returned to her home to get her belongings, then voluntarily admitted herself to Charter later that day. Schlotfeldt was diagnosed with major depressive disorder by Dr. Anil Batra. The next day, Dr. Gilles Desmarais examined Schlotfeldt. Desmarais was an independent doctor who was filling in for a Charter psychiatrist, but was not employed by Charter. Desmarais determined that Schlotfeldt was suicidal. Schlotfeldt said she wanted to go home, but Desmarais urged her to stay at Charter. Desmarais allowed Schlotfeldt to return home about two days later once the effects of the alcohol and methamphetamine had worn off. Several months later, Schlotfeldt sued Charter and Desmarais, alleging, among other things, that she had been falsely imprisoned. The trial court held that, as a matter of law, Charter could be held vicariously liable for Desmarais’s acts, and gave the jury this instruction. The jury found Charter and Desmarais liable for false imprisonment, awarding Schlotfeldt $50,000 in damages. Schlotfeldt and Charter appealed.