New York Court of Appeals

Flora A. Schrempf, as of Albert R. Schrempf v. State of New York

November 19, 198566 N.Y.2d 289

Summary

The New York Court of Appeals reversed the Appellate Division and dismissed the wrongful‑death claim alleging the State’s negligent release of a mental patient. The Court held that the State psychiatrist’s professional medical judgment is insulated from negligence liability, and therefore the State cannot be held liable for the third‑party assault. The decision rests on the principle that when the State performs a proprietary medical function, it is subject to the same standard of care as private providers, but professional judgment errors do not constitute actionable negligence.