Nguyen v. Massachusetts Institute of Technology
96 N.E.3d 128, 479 Mass. 436 (2018)
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Rule of Law:
A university has a special relationship with a student creating a duty to take reasonable measures to prevent suicide only when the university has actual knowledge of a student's suicide attempt that occurred while enrolled or recently before matriculation, or of a student's stated plans or intentions to commit suicide.
Facts:
- Han Duy Nguyen was a twenty-five-year-old graduate student at the Massachusetts Institute of Technology (MIT) who lived off-campus.
- In 2007, two years before his death, Nguyen sought help from MIT for test-taking problems but repeatedly declined referrals to MIT Mental Health, citing stigma and his preference for his own off-campus clinicians.
- In September 2007, Nguyen disclosed to MIT Dean David W. Randall a history of depression and two prior suicide attempts that occurred during his undergraduate years at a different university, but denied any present suicidal ideation.
- Nguyen gave Randall permission to contact his off-campus psychiatrist but quickly revoked it, stating he wanted to keep his mental health and academic problems separate.
- From 2006 to 2009, Nguyen was treated by at least nine private mental health professionals unaffiliated with MIT, none of whom believed he was at an imminent risk of suicide.
- Professors Birger Wernerfelt and Drazen Prelec were aware of Nguyen's academic struggles, test anxiety, and insomnia, but were not aware of his history of depression or prior suicide attempts.
- In January 2009, Wernerfelt urged faculty to pass Nguyen on his general examinations, stating they might have 'blood on their hands' if Nguyen were to fail, which Wernerfelt later characterized as a metaphorical concern.
- On June 2, 2009, shortly after a critical telephone call with Wernerfelt regarding an unprofessional email, Nguyen jumped from the roof of an MIT building, resulting in his death.
Procedural Posture:
- Dzung Duy Nguyen, as administrator of his son's estate, commenced a wrongful death action against MIT and three employees in the Superior Court Department in 2011.
- The defendants moved for summary judgment, and the plaintiff filed a cross motion for summary judgment.
- The Superior Court judge granted the defendants' motion for summary judgment and denied the plaintiff's cross motion.
- The plaintiff appealed the judgment, and the Supreme Judicial Court of Massachusetts granted the plaintiff's application for direct appellate review.
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Issue:
Does a university and its employees owe a student a duty of care to prevent suicide when the university is aware of the student's history of depression and academic struggles, but not of any recent suicide attempts or specific, stated plans to commit suicide?
Opinions:
Majority - Kafker, J.
No. A university and its employees do not owe a student a duty of care to prevent suicide under these circumstances. While the court establishes that a special relationship creating a duty to prevent suicide can exist between a university and its student, that duty is triggered only by very specific circumstances: the university's actual knowledge of a student’s suicide attempt while enrolled or recently before matriculating, or the student's stated plans or intentions to commit suicide. Here, those conditions were not met. Nguyen's prior suicide attempts were several years old and occurred before he enrolled at MIT. He never communicated any current suicidal plans or intentions to any MIT employee; in fact, he denied present suicidal ideation. He was an adult graduate student living off-campus who expressly rejected MIT's mental health services in favor of his own private treatment, and he explicitly asked the university to keep his academic and mental health issues separate. The professors' knowledge of academic stress and one professor's metaphorical 'blood on their hands' comment did not rise to the level of actual knowledge of a stated suicide plan required to trigger a legal duty. Therefore, the defendants had no special relationship with Nguyen that would impose a duty to prevent his suicide.
Analysis:
This decision establishes a new, narrow duty of care for universities regarding student suicide in Massachusetts, moving away from a broad 'in loco parentis' model. By creating a specific, knowledge-based trigger for this duty, the court provides a clear but high threshold for liability, balancing the protection of vulnerable students with respect for the privacy and autonomy of adult students. The ruling gives universities a defined framework, clarifying that they are not expected to be guarantors of student safety but must take reasonable steps when faced with specific, high-risk indicators like a recent attempt or a stated plan. Future litigation in this area will likely focus on interpreting what constitutes 'actual knowledge,' 'recently before matriculation,' and a 'stated plan or intention.'
