CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Jun 28, 1967

Weglarz v. State

This case involves an appeal from a judgment that dismissed a claim for damages against the State of New York. The claim arose from the suicide of Theodore Weglarz, who died after escaping from Pilgrim State Hospital. The claimant alleged negligence against the State for inadequate supervision, care, and surveillance, arguing that a more thorough review of medical records and a patient history from the spouse would have revealed suicidal tendencies. However, the Court of Claims determined that the supervising psychiatrist's decision to transfer the decedent to an open ward was a reasonable medical judgment, as no suicidal tendencies were apparent from his examination or available records. The judgment affirming the dismissal of the claim was upheld.

SuicideMental Health CareHospital NegligencePsychiatric MalpracticeForeseeability of HarmPatient EscapeWrongful DeathMedical JudgmentState LiabilityOpen Ward Policy
References
5
Case No. MISSING
Regular Panel Decision

Claim of Altes v. Petrocelli Electric Co.

The case involves an appeal from a Workers' Compensation Board decision denying death benefits to a claimant whose decedent committed suicide after a work-related injury. The Board concluded there was no causal relationship and that severe depression was insufficient for a suicide claim. The appellate court found the Board applied an incorrect legal standard, stating that depressive reactions can qualify as 'brain derangement' and a work-related injury only needs to be a 'contributing cause' to the ensuing suicide. The court reversed the Board's decision and remitted the matter for further proceedings consistent with the correct legal standard.

Suicide ClaimDeath BenefitsCausationDepressionMental InjuryWork-Related InjuryLegal Standard ErrorAppellate CourtRemittal
References
3
Case No. MISSING
Regular Panel Decision

Koenigsmark v. State

Claimant, with a history of schizophrenia and suicidal tendencies, escaped Elmira Psychiatric Center and attempted suicide. The dissent argues that the Court of Claims erred in dismissing the claim, asserting that Elmira was negligent. The negligence stemmed from systemic failures in patient record-keeping, communication of doctor's orders, reporting changes in patient behavior, and facility security. These omissions, according to the dissent, constituted common-law negligence, not mere errors in medical judgment, warranting a reversal of the lower court's dismissal and remittal for a trial on damages.

negligencepsychiatric caresuicide attempthospital liabilitypatient supervisionmedical malpracticemental health facilityrecord keeping failurecommunication breakdownsecurity inadequacy
References
7
Case No. MISSING
Regular Panel Decision

Johnson v. Nassau University Medical Center

This action concerns medical malpractice and wrongful death following a patient's suicide. The plaintiff, as the decedent's executor, appealed an order granting summary judgment to defendants Kathryn Zajac, a social worker, and Catholic Charities, her employer. The decedent, suffering from depression, expressed suicidal ideation to Zajac, who then consulted psychiatrist Kamil Jaghab. Jaghab determined a high suicide risk and advised hospital referral. The decedent was transported to Nassau University Medical Center and examined by psychiatrist Mukesh Prakash Sharoha, who, unaware of the specific suicide plan due to lack of communication from the Clinic, discharged him. The decedent committed suicide the next day. The appellate court found triable issues of fact regarding Zajac's duty to communicate with the hospital and follow up, reversing the lower court's grant of summary judgment.

medical malpracticewrongful deathsuicide preventiondepression treatmentsocial worker negligencepsychiatric assessmentvicarious liabilitysummary judgment motionprofessional standard of careproximate causation
References
3
Case No. MISSING
Regular Panel Decision

In re Evan Y.

The Family Court of Tioga County found a child, born in 1994, to be abused by his father (respondent) based on the child's out-of-court statements of being repeatedly fondled and exhibited troubling behaviors such as sexual acting out, nightmares, bed-wetting, and suicidal tendencies. Petitioner initiated this child abuse proceeding, and the respondent, who had a prior neglect adjudication, chose not to testify at the fact-finding hearing. Expert witnesses, clinical social workers Mary Bado and Sarah Walsh, provided corroborating testimony that the child's behaviors were consistent with sexual abuse. Family Court credited this expert testimony and found sufficient corroboration for the child's statements. The respondent appealed the finding of sexual abuse, but the appellate court affirmed the Family Court's order, noting the permissible inference against the non-testifying respondent and the ample corroborative evidence from the expert witnesses.

child abusesexual abuseFamily Court Act Article 10corroborationexpert testimonyout-of-court statementschild witnessesappellate reviewparental rightssexual acting out
References
9
Case No. ADJ10275361
Regular
Jan 27, 2020

RUSSELL MCFADDEN (deceased); RENEE MCFADDEN, JAZMINE MCFADDEN, and RUSSELL MCFADDEN, II vs. KEOLIS TRANSIT AMERICA; LIBERTY MUTUAL INSURANCE COMPANY

The Workers' Compensation Appeals Board affirmed a judge's decision denying a death benefit claim for Russell McFadden, who died by suicide. The applicant contended his death resulted from an industrial psychiatric injury due to occupational stress. Medical evidence indicated that industrial factors were only a 35% cause of the decedent's psychiatric disorder, with significant pre-existing conditions and drug use being the predominant causes. Furthermore, the Board found no evidence that the suicide was an irresistible impulse, distinguishing it from cases where an industrial injury directly causes a mental condition that prevents resistance to suicide. Therefore, the claim was denied based on the psychiatric injury not being predominantly industrially caused and the suicide not meeting the criteria for compensability.

Workers Compensation Appeals BoardRenee McFaddenKeolis Transit AmericaLiberty Mutual Insurance CompanyADJ10275361Opinion and Decision After ReconsiderationIndustrial Psychiatric InjuryOccupational Stress and StrainCompensable Death ClaimLabor Code Section 3600(a)(6)
References
6
Case No. MISSING
Regular Panel Decision
Mar 28, 2014

Gallen v. County of Rockland

This case concerns an appeal by defendants Jay L. Lombard and Brain Behavior Center-Rockland from the denial of their motion for summary judgment in a medical malpractice and wrongful death action. The plaintiff's decedent, after a suicide attempt, was discharged from Valley Hospital with a safety contract. The same day, he was seen by defendant Lombard, a neurologist, who performed a suicide assessment, prescribed medication, and concluded there was no immediate risk, but the decedent committed suicide a week later. The Supreme Court denied the defendants' motion for summary judgment, and the appellate court affirmed, finding a triable issue of fact regarding whether Lombard departed from good medical practice by failing to obtain prior records and conducting an inadequate suicide assessment.

Medical MalpracticeWrongful DeathSuicide AssessmentNeurologist LiabilitySummary JudgmentAppellate ReviewStandard of CareProximate CausePatient DischargePsychiatric Treatment
References
6
Case No. MISSING
Regular Panel Decision
Nov 05, 2002

Claim of Potter v. Curtis Lumber Co.

The claimant's decedent, a former marketing design manager for Curtis Lumber, committed suicide after experiencing work-related stress. The Workers’ Compensation Board awarded the claimant death benefits, finding the suicide was precipitated by a depressive illness causally linked to severe workplace stress. Curtis Lumber and its workers' compensation carrier appealed, arguing the stress was not greater than that usually found in a normal work environment and that lawful personnel decisions caused the suicide. The Appellate Division affirmed the Board's decision, concluding that the testimony of a board-certified psychiatrist provided substantial evidence that the decedent's suicide was causally related to abnormal work-related stress and implicitly rejecting the carrier's defense under Workers’ Compensation Law § 2 (7).

SuicideWork-Related StressDepressive IllnessWorkers' Compensation Death BenefitsCausal RelationshipSubstantial EvidenceMedical Expert TestimonyPersonnel DecisionsAppellate ReviewAffirmed Decision
References
11
Case No. 2026 NY Slip Op 00962
Regular Panel Decision
Feb 19, 2026

Beadell v. Eros Mgt. Realty LLC

This case concerns the liability of a hotel (Eros Management Realty, LLC and Tryp Management Inc.) for the suicide of a guest, Dr. Noah Beadell, who jumped from his 11th-floor room. His family, aware of his suicidal ideation, contacted the hotel multiple times, requesting staff to check on him and, later, to immediately call 911 for emergency intervention. Although hotel staff checked on the guest and eventually called 911, there was a significant delay (25 minutes) after the family's urgent request for police intervention. The plaintiffs, the decedent's mother and wife, argued the hotel assumed a duty to act with due care and breached it, leading to a lost opportunity to prevent the suicide. The Court of Appeals affirmed the Appellate Division's decision, holding that the hotel did not assume a duty to prevent the suicide under the circumstances, and that the plaintiffs' reliance on the hotel's promise to call 911 was not reasonably foreseeable to establish an assumed duty.

SuicideNegligenceAssumed DutyHotel LiabilityWrongful DeathProximate CauseForeseeabilityMental Health CrisisEmergency InterventionDelayed Response
References
36
Case No. 2024 NY Slip Op 02496 [229 AD3d 43]
Regular Panel Decision
May 07, 2024

Beadell v. Eros Mgt. Reality, LLC

This case concerns the suicide of Noah Beadell, a hotel guest, after his family notified hotel staff of his suicidal ideations and requested police assistance. Plaintiffs, Beadell's widow and sister, filed a negligence and wrongful death action against the hotel owner and management, alleging they assumed a duty to prevent suicide by agreeing to check on Beadell and promptly contact the police, but negligently delayed doing so. The Supreme Court initially denied the defendants' motion for summary judgment. However, the Appellate Division, First Department, reversed this decision, holding that the hotel did not owe or assume a duty of care to Beadell that would have placed him in a more vulnerable position. The court also concluded that plaintiffs failed to demonstrate proximate cause, deeming their expert testimonies on the preventability of the suicide and the impact of the delay as speculative, especially since police arrived before Beadell jumped. A dissenting opinion argued that the hotel's promise to call the police created an assumed duty, and a jury could reasonably find the delay contributed to Beadell's death.

Hotel LiabilitySuicide PreventionAssumed DutyNegligenceWrongful DeathProximate CauseSummary JudgmentExpert TestimonyAppellate ReviewPremises Liability
References
78
Showing 1-10 of 80 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational