Porter v. Murphy

Delaware Superior Court · Torts

TortsWrongful deathProximate causeSuicideJury instructionsJury misconductproximate causesuicide

Facts

The decedent was rear-ended by defendants' bus while stopped at an intersection and later became depressed. Plaintiffs claimed the accident-related injuries and resulting financial and work difficulties caused depression that led to his suicide about a year later. Plaintiffs' expert testified that the decedent's suicide resulted from depression stemming from the accident and an inability to see alternatives, but the plaintiffs' evidence did not suggest he acted under an uncontrollable impulse. Evidence also showed the decedent planned the suicide by saying goodbye to family members and waiting until his wife was asleep.

Issue

What proximate-cause standard should govern a wrongful-death claim alleging that negligently inflicted injuries led to the victim's later suicide? Also, does a new trial become warranted when, without court or counsel approval, a bailiff provides a dictionary to the deliberating jury?

Rule

Where a defendant's negligence causes mental illness that results in an uncontrollable impulse to commit suicide, the defendant may be liable for the death. But if the negligence causes only a mental condition in which the injured person realizes the nature of suicide and has the power to control the act if he so desires, the suicide is an independent intervening force and the defendant is not liable. An unauthorized dictionary in the jury room does not warrant a new trial absent a showing of prejudice.

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In Columbus, Ohio, a delivery van owned by Lakeview Parcel Service negligently struck Evan Mills, causing chronic pain and a severe psychiatric decline. Three months later, during a sudden psychotic episode, Evan ran from his house in a panic and leapt from a second-story window before family members could restrain him; his psychiatrist testifies the injury-induced mental illness made it impossible for him to resist the impulse.

If Evan's estate brings a wrongful-death negligence claim against Lakeview Parcel Service, which is the strongest argument for allowing the claim to go to the jury?

Explanation. The governing rule is a special proximate-causation rule for suicide cases. A defendant may be liable when negligence causes mental illness that results in an uncontrollable impulse to commit suicide. The court rejected use of an ordinary but-for instruction and did not adopt a broad foreseeability-only rule. Lack of understanding of the act is one possible Restatement-style formulation, but the majority adopted the uncontrollable-impulse formulation as the operative instruction. (Derived from Porter v. Murphy (n.d.).)