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Case Law Database

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

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

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. 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
Case No. MISSING
Regular Panel Decision

Harrison v. Metropolitan Life Insurance

Plaintiff Gail Harrison sued Metropolitan Life Insurance Company, Horizon Blue Cross Blue Shield of New Jersey, and Empire Blue Cross Blue Shield of New York after her husband, John H. Harrison, committed suicide. She sought benefits from his life insurance plan, which the defendants denied based on a suicide exclusion. The case was removed from New York Supreme Court to federal court. Harrison alleged breach of contract, common law fiduciary duties, violation of New York Insurance Law § 3203(b)(1)(B), and breach of ERISA fiduciary duties under § 1132(a)(3). The court granted the defendants' motion to dismiss Harrison's common law claims (preempted by ERISA), her New York Insurance Law claim (not applicable to group plans and no private right of action), and her ERISA § 502(a)(3) claim (seeking monetary relief adequately addressed by § 502(a)(1)(B)). However, the court denied dismissal for her claim under ERISA § 502(a)(1)(B), finding it premature to rule on the reasonableness of the defendants' interpretation of the 'suicide' exclusion to include suicide committed while insane, pending further discovery.

ERISA Benefits ClaimLife InsuranceSuicide ExclusionBreach of Fiduciary DutyCommon Law PreemptionMotion to DismissPlan Administrator DiscretionArbitrary and Capricious StandardDe Novo ReviewConflict of Interest
References
57
Case No. ADJ991157
Regular
Mar 15, 2010

GLENDA STAFFORD vs. ARMORED TRANSPORT, ESIS SOUTHFIELD

The Workers' Compensation Appeals Board (WCAB) granted reconsideration and reversed a prior decision finding the decedent's suicide compensable. The Board determined that the employer's investigation into missing funds, which led to the suicide, constituted a lawful, nondiscriminatory, good faith personnel action under Labor Code section 3208.3(h). Therefore, compensation for the suicide is barred, and the applicant is entitled to take nothing.

Workers' Compensation Appeals BoardSuicideIndustrial InjuryDeath BenefitDependentPersonnel ActionGood Faith InvestigationIrresistible ImpulseLabor Code Section 3208.3(h)Psychiatric Injury
References
5
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
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