Stolarski v. Family Services of Westchester, Inc.
Plaintiff Arlene Stolarski appealed a judgment from the Supreme Court, Westchester County, which dismissed her cause of action to recover damages for conscious pain and suffering in a wrongful death action. The decedent, after an apparent suicide attempt and subsequent consultations with Family Services of Westchester, Inc., died by suicide shortly after. Plaintiff alleged negligence by Family Services in treating the decedent's depression, causing conscious pain and suffering between October 19, 2005, and October 28, 2005. The Supreme Court initially granted the defendant's motion to dismiss, reasoning that such damages couldn't be recovered in a wrongful death action and that the depression was pre-existing. The Appellate Division reversed, holding that a cause of action for personal injuries, including conscious pain and suffering due to professional malpractice, survives the decedent's death and may be recovered by her estate, and that pre-existing conditions do not preclude proving exacerbation by alleged negligent treatment.