Supreme Court of Pennsylvania

Estate of Frederick v. Geisinger Medical Ctr

April 25, 2025

Summary

In this dissent, Justice Wecht argues that the Mental Health Procedures Act requires a written application and formal acceptance before a person becomes a voluntary inpatient, and because Westley Wise never completed those steps he remained a voluntary outpatient whose care falls outside the Act; consequently the hospitals did not participate in a decision that would trigger liability under Section 114. The dissent rejects the majority’s view that a mere request for inpatient treatment creates liability.