Pennsylvania Supreme Court Broadens MHPA Immunity to Include Ordinary Negligence in Physical Care During Involuntary Commitment

The Pennsylvania Supreme Court has recently expanded the scope of provider immunity under the Mental Health Procedures Act (MHPA), holding that the statute can shield providers from ordinary negligence claims arising from medical care for physical ailments provided during involuntary commitment. The case arose from a wrongful death and survival action following the death of a patient involuntarily committed for dementia-related aggression who developed severe pressure ulcers.

Under 50 P.S. § 7114(a), facilities and practitioners participating in decisions to examine or treat individuals under the MHPA are immune from civil and criminal liability, absent a showing of willful misconduct or gross negligence.

As § 114 does not define “treat,” the court looked to Section 104 of the MHPA, interpreting “treatment” to include medical care necessary to maintain “decent, safe, and healthful living conditions.” The court concluded that care for physical conditions is covered when it is coincident to the patient’s mental health treatment, even if the condition did not result from psychiatric care or advance psychiatric recovery.

This decision significantly broadens the precedent established in Allen v. Montgomery Hospital, 696 A.2d 1175 (Pa. 1997). While Allen provided immunity for physical conditions caused by psychiatric care (such as medication side effects), Wunderly extends that protection to general medical care that simply occurs during the same timeframe as the commitment (such as treatment for pressure ulcers).

The dissent warned that the majority’s interpretation risks lowering the standard of care for involuntarily committed patients by immunizing ordinary medical malpractice based solely on commitment status. The dissent argued that the patient’s pressure ulcers arose independently of his mental health condition and should not fall within MHPA immunity.