Sullivan v. Truist Bank, 2024 WL 422667 (E.D. Pa. Feb. 5, 2024)

U.S. District Court for the Eastern District of Pennsylvania Held that Suicide Is Not a Legitimate Basis for Recovery in Wrongful Death Cases and Cannot Establish Causation

The plaintiff-estate brought an action against the defendant-bank that raised negligence, vicarious liability, wrongful death and survival action claims. The plaintiff-estate claimed that the decedent was the victim of an online extortion scheme and suffered a wrongful death that was caused by the defendant-bank. Specifically, after the defendant-bank refused to release funds to the extortioners, the decedent committed suicide. After the case was removed to federal court, the defendant-bank filed a motion to dismiss. 

In ruling upon the motion to dismiss, the federal court held that the plaintiff-estate could not plausibly allege that the defendant-bank caused the decedent’s death. The federal court found that, generally, suicide was not a recognized legitimate basis for recovery in wrongful death cases since suicide is an independent intervening act that is so extraordinary it is not foreseeable. The federal court reasoned that only in limited situations will suicide be recognized as a legitimate basis (such as a hospital or mental health institution in which the custodial relationship creates a special duty of care), none of which applied in this case. The federal court ruled that since there was no causation connection between the defendant-bank’s conduct and the alleged injuries, the plaintiff-estate’s negligence claims failed. The federal court, therefore, granted the defendant-bank’s motion to dismiss. 

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