Wunderly v. Saint Luke’s Hosp. of Bethlehem, 2025 Pa. LEXIS 1707 (October 23, 2025) Mundy, J.
Section 114 of the Mental Health Procedures Act (“MHPA”) provides protection, absent willful misconduct or gross negligence, from civil and criminal liability to institutions and individuals “who participate[] in a decision that a person be examined or treated” under the Act. See 50 P.S. § 7114(a) (“Immunity Provision”). In this appeal, we address the scope of the term “treated” as used in the Immunity Provision, specifically whether immunity applies where a hospital provides medical care for a physical ailment of a patient admitted to its facility for mental health treatment. For the reasons that follow, we conclude that the Superior Court properly affirmed the trial court’s decision granting the hospital’s motion for judgment on the pleadings under the Immunity Provision of the MHPA.
In June 2021, Kathryn J. Wunderly (“Appellant”), Executrix of the Estate of Kenneth E. Wunderly (“Decedent”), filed a wrongful death and survival action raising claims of negligence and corporate negligence against Saint Luke’s Hospital of Bethlehem and its affiliates (“St. Luke’s”) related to the care and treatment of Decedent while a patient at one of its facilities. Appellant’s complaint alleged that, on or about September 28, 2019, Decedent was admitted to St. Luke’s with Stage I pressure ulcers to his right and left buttocks. During this hospital stay, Decedent acquired pressure related skin breakdown, pressure wounds, and the deterioration of existing pressure wounds. She further alleged that, on or around October 14, 2019, Decedent, while still a patient at St. Luke’s, was documented with unstageable pressure ulcers to his right buttocks and posterior perineum, and deep tissue injury pressure wounds to his left buttocks and left heel. He
was transferred to another facility, Above & Beyond, Inc., that same day and died ten days later. Appellant alleged that Decedent’s pressure ulcers and wounds caused and/or contributed to his physical decline and ultimate death.
St. Luke’s filed an answer with new matter, alleging that Decedent was involuntarily admitted to its facility under Section 302 of the MHPA and remained in its care under Section 303. Because of this, St. Luke’s asserted that, absent allegations of willful misconduct or gross negligence, it was immune from liability under the Immunity Provision of the MHPA. Appellant, in her reply to the new matter, denied these averments as conclusions of law or mixed conclusions of law and fact that did not warrant a response. St. Luke’s moved for judgment on the pleadings.
Appellant appealed to this Court. We granted review to consider the following issue: “Did the Superior Court err in affirming the [t]rial [c]ourt’s grant of judgment on the pleadings in favor of St. Luke’s because the [Immunity Provision] of the [MHPA] do[es] not apply to [Appellant]’s claims?” Wunderly v. Saint Luke’s Hosp. of Bethlehem, Pa., 310 A.3d 715 (Pa. 2023) (per curiam).
Appellant asserts that the Immunity Provision of the MHPA does not apply to the claims alleged in the complaint because they do not relate to the treatment provided for Decedent’s mental health conditions. Appellant explains that the MHPA provides immunity to physicians and other hospital staff “who participate[] in a decision that a person be examined or treated[.]” Appellant’s Brief at 14 (quoting 50 P.S. § 7114(a)). She further observes that “treatment” as defined by Section 104(a) includes “care and other services that supplement treatment and aid or promote such recovery” from mental illness. Id. at 15 (quoting 50 P.S. § 7104). Appellant highlights the fact that this Court has found that the MHPA is “limited by its own terms” and “does not automatically apply in every situation involving a patient with a history of mental illness.” Id. at 14 (quoting Dean, 225 A.3d 859 at 871).
Decedent was unquestionably being treated by St. Luke’s for a mental health condition. He was involuntarily admitted to St. Luke’s under Section 302 for dementia related aggression and remained in its care under Section 303. Notwithstanding, Appellant maintains that the MHPA does not apply because the claims alleged in the complaint do not relate to the treatment of Decedent’s mental health conditions. We disagree. At the outset, the definitions of “adequate treatment” and “treatment” provided in Section 104 make clear that the MHPA applies to various aspects of care. “Adequate treatment” is defined, in part, as that which is “designed and administered to alleviate a person’s pain and distress” and “maximize the probability of [the patient’s] recovery from mental illness.” 50 P.S. § 7104. Where inpatient treatment is involved, the definition includes accommodations such as “diet, heat, light, sanitary facilities, clothing, recreation, education and medical care as are necessary to maintain decedent, safe and healthful living conditions.” Id. (emphasis added). “Treatment” includes direct care of a mental illness, as well as “care and other services that supplement treatment and aid or promote such recovery [from a mental illness].” Id. As noted above, these definitions
make clear that treatment under the Immunity Provision encompasses not only that which is specifically directed toward recovery from a mental illness, but also basic care needs and other foreseeable medical issues that may or may not directly relate to mental health treatment but require attention during the patient’s admission.
As a final note, today’s decision should not be interpreted as immunizing virtually all medical treatment provided to a patient with mental health issues. The MHPA limits immunity to medical treatment that is coincident to mental health treatment. While it is difficult to enounce specific parameters given the fact-specific nature of these cases, there will be circumstances where medical treatment is so tenuously connected to the mental health treatment that the Immunity Provision does not apply. The definitions of “treatment” and “adequate treatment” are broad but not without limitation. Here, we have determined that St. Luke’s actions regarding Decedent’s pressure ulcers constituted treatment under the MHPA, as it was “coincident” to his mental health treatment for dementia. Pressure ulcers, in particular, are a rather foreseeable complication during an elderly patient’s inpatient treatment for a mental health condition and one that is consistent with the scope of the term “treated” under the Immunity Provision. We trust that our trial courts will similarly be able to discern whether the treatment of other physical ailments is coincident or not based on the specific facts of a case. Because St. Luke’s conduct in this case qualifies as treatment, St. Luke’s may not be held liable under the Immunity Provision of the MHPA absent willful misconduct or gross negligence. Appellant has failed to make any such allegations in the complaint, and the Superior Court affirmed the trial court’s decision concluding that the allegations in the complaint sounded in ordinary negligence and were insufficient as a matter of law to support a finding of gross negligence or of willful conduct. Moreover, this specific issue was not included in this Court’s order granting allocatur. We agree with the Superior Court’s decision finding judgment on the pleadings proper.
For the foregoing reasons, this Court concludes that St. Luke’s actions in this case qualify as treatment under the MHPA. Because Appellant failed to demonstrate gross negligence or willful indifference, St. Luke’s is immune from suit. We therefore affirm the order of the Superior Court granting St. Luke’s motion for judgment on the pleadings.
Chief Justice Todd and Justices Wecht and Brobson join the opinion. Justice Donohue files a dissenting opinion in which Justices Dougherty and McCaffery join.
Dissent by: DONOHUE
