## Facts

- Kurt Meier, who had recently attempted suicide, was admitted to Ross General Hospital’s psychiatric unit under the care of psychiatrist Dr. James M. Stubblebine.
- The hospital used an “open-door” psychiatric policy allowing patients relative freedom and avoiding physical restraints.
- Meier was placed in a second-floor room with a fully openable window.
- Meier died by suicide by jumping head-first through the open window.
- Meier’s widow and minor children sued the hospital and Dr. Stubblebine for wrongful death, alleging negligent failure to protect him from foreseeable self-harm.
- At trial, defendants presented expert testimony that the open-door policy met accepted psychiatric practice; plaintiffs elicited testimony suggesting window restrictions could have been used without undermining the therapeutic approach.
- Plaintiffs requested a res ipsa loquitur instruction stating that res ipsa could apply even if the decedent participated in the events, so long as the evidence excluded his conduct as the responsible cause; the court gave only a general res ipsa instruction.
- The jury returned a verdict for defendants, and judgment was entered accordingly.

## Issues

1. Whether the trial court committed prejudicial error by refusing to instruct that plaintiffs could rely on res ipsa loquitur despite the decedent’s suicidal act if his conduct was not the responsible cause of death.
2. Whether, given defendants’ knowledge of suicide risk and placement of Meier in a room with an openable second-story window, the jury should have been permitted to apply a properly qualified (conditional) res ipsa inference without requiring expert testimony.

## Decision

- The California Supreme Court held the trial court erred by refusing the requested explanatory res ipsa instruction.
- The Court held a properly qualified conditional res ipsa instruction was warranted on these facts.
- The Court concluded the instructional error was prejudicial because it impaired plaintiffs’ ability to have the jury consider an inference of negligence consistent with defendants’ duty to protect a suicidal patient from self-harm.
- Judgment for defendants was reversed and the case remanded for a new trial with appropriate instructions.

## Legal Principles

- Hospitals and treating physicians must use reasonable care to prevent foreseeable self-injury when they know facts indicating a mentally disturbed patient is likely to harm himself absent protective measures.
- Res ipsa loquitur is not barred merely because the injured person’s own conduct physically contributed to the injury when the alleged duty includes protection from that very conduct (voluntary or involuntary).
- In such cases, the jury should be instructed that plaintiff may rely on res ipsa if the evidence permits a finding that the decedent’s conduct was not the responsible cause of the harm.
- Expert testimony is not invariably required to support a res ipsa inference in a medical setting when the alleged negligence concerns a readily understandable safety condition rather than technical medical treatment.

## Conclusion

The court ordered a new trial because the jury should have been instructed that res ipsa loquitur could apply to a suicidal patient’s death where caregivers had a duty to prevent self-harm and the circumstances permitted an inference that inadequate precautions, not the patient’s act alone, were the responsible cause.


Meier v. Ross Gen. Hosp., 445 P.2d 519 (Cal. 1968)