Binkley v. Allina Health System

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law