Matos v. Geisinger Med. Ctr., 2025 Pa. LEXIS 599 (Pa. Supreme Ct., April 25, 2025) (Todd, J.)
CHIEF JUSTICE TODD
In this consolidated appeal, our Court is asked to decide whether our decision in Leight v. UPMC, 664 Pa. 60, 243 A.3d 126 (Pa. 2020) (“Leight II”), bars a suit by a third party under Pennsylvania’s Mental Health Procedures Act (“MHPA”)1 for alleged willful misconduct or gross negligence by treatment facilities 2 and their medical staff in failing to admit an individual who presented himself and verbally requested voluntary inpatient treatment for a serious mental health crisis he was experiencing. After careful review, we conclude that Leight II does not bar such a suit, and that the MHPA does not require a person seeking voluntary inpatient treatment to make a written request for such treatment in order to trigger a duty on the part of treatment facilities to engage in the evaluation and treatment processes mandated by the MHPA. Consequently, we affirm the order of the Superior Court which reached the same conclusion.
Subsequently, on August 15, 2013, Administrator filed this action under Section 114(a) of the MHPA against Geisinger, Alley, and the aforementioned medical personnel in their employ who were involved in the diagnosis and treatment of Wise, all Appellants herein. In his complaint, Administrator alleged that they engaged in gross negligence and/or willful misconduct in denying Wise’s requests for inpatient treatment.
In the absence of willful misconduct or gross negligence, a county administrator, a director of a facility, a physician, a peace officer or any other authorized person who participates in a decision that a person be examined or treated under this act, or that a person be discharged, or placed under partial hospitalization, outpatient care or leave of absence, or that the restraint upon such person be otherwise reduced, or a county administrator or other authorized person who denies an application for voluntary treatment or for involuntary emergency examination and treatment, shall not be civilly or criminally liable for such decision or for any of its consequences.
For all of the aforementioned reasons, we hold that, under the MHPA, an individual’s act of presenting himself to an approved facility and orally requesting admission for voluntary inpatient treatment is sufficient to constitute [*56] an application for voluntary inpatient treatment for purposes of the MHPA, such that Section 114(a) imposes liability on health care providers for willful misconduct or gross negligence in denying such treatment.34 Accordingly, we affirm the order of the Superior Court. Order affirmed. Jurisdiction relinquished. Justices Donohue, Dougherty, Mundy, Brobson and McCaffery join the opinion. Justice Wecht files a dissenting opinion.