## Facts

- Michael Weathers had a documented history of depression, threats of self-harm, and multiple overdose episodes.
- After an Elavil overdose on September 14, 1984 (with an apparent suicide note), he was admitted to Memorial Hospital and treated by Dr. Robert D. Pilkinton, a general physician.
- Family members testified that Dr. Pilkinton indicated he could treat the medical condition but that psychological problems were outside his field.
- Mr. Weathers was discharged after approximately eight days.
- In early November 1984, Mr. Weathers experienced additional overdose incidents, including one on November 10, 1984, leading to another admission to Memorial Hospital under Dr. Pilkinton’s care.
- After discharge from the November 1984 admission, Dr. Pilkinton recommended outpatient mental-health treatment; Mr. Weathers returned to work and appeared to be in a reasonably good mood.
- On November 28, 1984, more than two weeks after discharge, Mr. Weathers fatally shot himself.
- The widow sued for wrongful death based on alleged medical negligence and for outrageous conduct, asserting Dr. Pilkinton should have secured psychiatric evaluation and involuntary commitment.
- Plaintiff offered expert testimony that the standard of care required psychiatric consultation and potential involuntary commitment given the suicide risk.

## Issues

1. Whether the evidence was sufficient to submit to a jury that Dr. Pilkinton’s alleged failure to obtain psychiatric evaluation/commitment was a proximate cause of Mr. Weathers’s death.
2. Whether a general physician, treating a patient episodically after suicide attempts and lacking custodial control after discharge, owes a duty extending to preventing a later intentional suicide.
3. Whether a directed verdict for the physician was proper under Tennessee’s standard requiring the strongest legitimate view of the evidence for the plaintiff and all reasonable inferences in her favor.

## Decision

- The Court of Appeals of Tennessee affirmed the directed verdict for Dr. Pilkinton.
- Applying the directed-verdict standard, the court held reasonable minds could not find the physician’s alleged omissions to be the legal/proximate cause of the suicide.
- The court treated the suicide as the immediate cause of death and declined to impose liability on the general physician under the circumstances, emphasizing limits on legal causation and duty in this setting.
- The court relied in part on the temporal gap and intervening circumstances: Mr. Weathers was discharged, living independently, returned to work, and later chose to end his life.
- Permission to appeal was denied by the Tennessee Supreme Court.

## Legal Principles

- A directed verdict is appropriate when, even taking the strongest legitimate view of the evidence for the nonmoving party and drawing all reasonable inferences in that party’s favor, reasonable minds could not differ on the dispositive issue.
- Proximate cause limits negligence liability to harms that are legally attributable to the defendant’s conduct; an adult’s later intentional suicide, outside custodial control and after discharge, may be too attenuated to be treated as legally caused by a treating physician’s earlier omissions.
- Absent special circumstances (such as custodial control, a psychiatric treatment role, or a clear statutory duty), Tennessee negligence law does not extend a general physician’s responsibility to preventing a patient’s subsequent, intentional suicide occurring weeks after treatment and discharge.
- Expert proof of a breach (e.g., failure to seek psychiatric consultation or commitment) does not, by itself, establish a jury question if legal/proximate causation is not supported on the record.

## Conclusion

The court affirmed judgment for the physician because the plaintiff’s proof did not establish that any alleged failure to pursue psychiatric intervention was a legally cognizable proximate cause of a suicide occurring weeks after discharge, when the patient was no longer under the physician’s control and acted intentionally.


Weathers v. Pilkinton, 754 S.W.2d 75 (Tenn. Ct. App. 1988)