Harris v. State
Adrienne D., a mentally disabled individual with a history of epileptic seizures, suffered severe burns in a State-certified family care home bathroom with a locked door that prevented outside access during an epileptic seizure. The Court of Claims initially found the State vicariously liable through its agents, the McNairs, the family care providers. On appeal, the court rejected the vicarious liability argument, establishing that family care providers are independent contractors. However, the court affirmed the judgment against the State based on its direct negligence in failing to provide a reasonably safe environment given Adrienne's known medical condition and the foreseeable risks posed by the non-accessible bathroom lock. The court emphasized the State's duty to protect patients while acknowledging the goals of normalization programs.