## Facts

- David Ragsdale received treatment at a medical clinic from nurse practitioner Trina West, with physician involvement alleged through consulting and clinic relationships.
- West prescribed Ragsdale multiple medications, including psychotropic or mood-altering drugs.
- With these medications in his system, Ragsdale shot and killed his wife, Kristy Ragsdale.
- Ragsdale pleaded guilty to aggravated murder.
- The Ragsdales’ minor children, through a conservator, sued the prescribing providers and clinic for negligence, alleging the prescription and management of medications caused or contributed to the homicide and resulting harm to the children.

## Issues

1. Whether health-care providers owe nonpatients a duty to exercise reasonable care when affirmatively prescribing medications that pose a risk of injury to third parties.
2. Whether the absence of a patient–provider relationship between the nonpatients and the providers bars a negligence claim at the duty stage.
3. Whether uncertainties about causation and liability limits should be addressed by denying duty or by breach/proximate-cause analysis and later procedural stages.

## Decision

- The Utah Supreme Court reversed the Rule 12(b)(6) dismissal and remanded for further proceedings.
- The court held that providers may owe a duty of reasonable care to foreseeable nonpatient third parties when the alleged negligence consists of affirmative prescription decisions creating a risk of third-party harm.
- The court rejected a categorical rule limiting medical duties to the patient alone in this context.
- The court declined to resolve collateral estoppel based on Ragsdale’s guilty plea because the district court had not decided that issue.

## Legal Principles

- Duty in negligence is a question of law focused on generally applicable standards and policy, and it is analytically distinct from breach and proximate cause.
- When a defendant engages in affirmative conduct that creates a risk of physical harm, a duty of reasonable care may extend to foreseeable victims, including certain nonpatients.
- Foreseeability informs duty at a general level; case-specific questions about what was foreseeable, whether the standard of care was breached, and whether the conduct caused the injury are addressed under breach and proximate cause.
- Policy concerns about expanded liability do not justify a categorical no-duty rule where traditional doctrines (breach, proximate cause, defenses, and case-dispositive motions) can limit liability in weak or speculative cases.

## Conclusion

The court held that health-care providers can owe a reasonable-care duty to foreseeable nonpatients harmed by risks created through affirmative prescription decisions, and it reinstated the children’s negligence claims for litigation of breach, causation, and related defenses on remand.


B.R. v. West, 275 P.3d 228 (Utah 2012)