Under Pennsylvania law, medical providers and facilities may be held liable for refusal to provide voluntary inpatient examination and treatment to a person who submits him or herself for examination and treatment when the refusal constitutes willful misconduct or gross negligence. In this case, Mr. Wise, a man with an extensive mental health history, presented himself for voluntary inpatient examination and treatment at Geisinger Medical Center and then Alley Medical Center three days later. Medical personnel at both facilities examined Mr. Wise but denied his requests for treatment despite Mr. Wise alleging telling both facilities that he felt “suicidal or homicidal” and that he was “going to snap.” On the night Mr. Wise was sent home from Alley, he murdered his girlfriend, Jessica Frederick. 

The administrator of Ms. Frederick’s estate filed suit against Geisinger, Alley and individuals employed by these entities, alleging the defendants were liable under the Mental Health Procedures Act (MHPA) for failing to diagnose Mr. Wise’s condition and for failing to initiate inpatient treatment. The defendants moved for summary judgment, arguing that the MHPA was not triggered because Mr. Wise never completed an application to commence the process for voluntary inpatient treatment, relying on precedent regarding involuntary treatment from Leight v. Univ. of Pittsburgh Phys., 243 A.3d 126 (Pa. 2020). The trial court denied the motions, and the defendants appealed. 

On appeal, the Pennsylvania Superior Court affirmed. The Matos court first compared the relevant voluntary and involuntary provisions under the MHPA, noting that a written application is a prerequisite to initiating the involuntary inpatient examination process. Indeed, this was the holding in Leight, where the Supreme Court held that liability may attach under the MHPA only if a written application was submitted by a physician. However, the court noted that because this written application prerequisite was “conspicuously absent” from the voluntary provisions, no such prerequisite was required to trigger the MHPA’s process for voluntary inpatient examination and treatment. Instead, the only prerequisite for voluntary inpatient examination and treatment is a person submitting him or herself to an approved facility, requesting examination and admission for inpatient treatment. Thus, the court distinguished Leight and found that, unlike involuntary examinations, where liability may attach only after a written application is submitted, no such requirement for a written application is required for voluntary examinations. 

Applying this framework to the case sub judice, the court found that the prerequisite for liability under the voluntary inpatient examination and treatment provisions of the MHPA was satisfied when Mr. Wise submitted himself to Geisinger and Alley. Thus, the Superior Court affirmed the trial court’s denial of the defendants’ motions for summary judgment, holding that they may be subject to liability if their conduct constituted willful misconduct or gross negligence.