Schrempf v. State

The State of New York (plaintiff) was found liable for the death of Albert Schrempf, who was stabbed to death by Joseph Evans while Evans was an outpatient of one of the state’s mental facilities. In the two years prior to Schrempf’s death, Evans had been admitted to state mental institutions six times, at times voluntarily, but mainly involuntarily following violent episodes. Evans’s primary diagnoses were manic depression and paranoid schizophrenia, which were generally stabilized by psychotherapy and medication. Evans began the year that he killed Schrempf as an inpatient following involuntary commitment, which ended at the end of January. That summer, Evans was placed on probation after breaking the windows at his mom’s house. Evans’s probation officer suggested that he resume psychiatric treatment. In September, Evans checked himself into a state facility after having delusions that others were trying to harm him. Evans was released to outpatient status based on a state psychiatrist’s judgment that Evans did not pose a risk to himself or others. The psychiatrist assigned Evans to a special outpatient clinic, where his medication could be monitored and Evans could see a resident psychiatrist regularly. However, shortly before the murder, the psychiatrist noted that Evans was not participating in the outpatient program, yet he was maintaining a part-time job without incident and had successfully completed a trial period of vocational rehabilitation at Schrempf’s clinic. Schrempf’s widow (defendant) filed the wrongful-death suit, alleging that the state negligently failed to involuntarily institutionalize Evans before he killed Schrempf. A state court of claims found in favor of Schrempf’s widow after hearing varying expert testimony regarding the appropriate treatment for Evans given the circumstances. The court concluded that the psychiatrist should have done “something” to prevent Schrempf’s death. The state appealed.