Estate of Frederick v. Geisinger Medical Ctr

Summary

The Supreme Court of Pennsylvania affirmed the Superior Court, holding that Leight II does not preclude a third‑party suit under the Mental Health Procedures Act and that an oral request for voluntary inpatient treatment satisfies the statutory ‘application’ requirement, thereby triggering liability under § 114(a) for willful misconduct or gross negligence. The Court also rejected the requirement that a written Form MH‑781 be completed before liability can attach.