Stack v. Saxton
455 So. 2d 1322, 9 Fla. L. Weekly 2017, 1984 Fla. App. LEXIS 15019 (1984)
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Rule of Law:
An actor's conduct is a legal cause of harm if it is a substantial factor in bringing about the harm, even if the actor did not foresee the specific manner or extent of the harm, unless it appears highly extraordinary in hindsight that the conduct would have caused the harm.
Facts:
- A court ordered the sheriff to transport a prisoner from jail to North Broward Hospital District's facility for a psychiatric evaluation and then return him to jail.
- At the hospital, an emergency room physician observed the prisoner was hallucinating and diagnosed him with potential "schizophrenic paranoia."
- After consulting an on-call psychiatrist, the hospital determined it had no secure beds and recommended the prisoner be sent to the Las Olas Rehabilitation Center for involuntary admission.
- Hospital staff informed the deputy sheriff of this plan, prepared the necessary transfer paperwork, and instructed the deputy to take the prisoner to Las Olas.
- The deputy complied and transported the prisoner to the Las Olas facility instead of returning him to the county jail as ordered.
- Weeks later, the prisoner escaped from the Las Olas facility.
- After his escape, the prisoner assaulted and injured a turnpike employee.
Procedural Posture:
- An injured turnpike employee sued the then-current sheriff in a state trial court for negligence.
- The sheriff filed a third-party complaint against North Broward Hospital District, alleging the hospital was responsible for the events leading to the injury.
- The trial court granted summary final judgment in favor of North Broward Hospital District on the third-party complaint.
- The sheriff, as the third-party plaintiff and appellant, appealed the summary judgment to the District Court of Appeal of Florida, Fourth District.
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Issue:
Does a hospital's recommendation and logistical arrangement for a mentally unstable prisoner's transfer to a third-party facility, in contravention of a court order to return the prisoner to jail, create a genuine issue of material fact as to whether the hospital's actions were a legal cause of harm resulting from the prisoner's subsequent escape?
Opinions:
Majority - Glickstein, Judge.
Yes. A hospital that affirmatively arranges for a mentally unstable prisoner to be transferred to a third-party facility, contrary to a court order, can be considered a legal cause of subsequent harm, precluding summary judgment. The court reasoned that the hospital "affirmatively interject[ed] itself into the chain of events" by undertaking the transfer of a prisoner it knew was potentially dangerous and required involuntary commitment. Citing the Restatement (Second) of Torts § 435, the court held that as long as the hospital's conduct was a "substantial factor" in causing the harm, it can be held liable even if it did not foresee the specific manner of the injury. Since it was not "highly extraordinary" that redirecting a mentally unstable prisoner from a secure jail could lead to harm, and because key facts about the hospital's role remained unresolved, the issue of causation was a question for the jury, not the judge.
Analysis:
This decision clarifies the scope of liability for third parties who, without having formal custody, intervene in the handling of a known dangerous individual. It establishes that an entity like a hospital can be a legal cause of subsequent harm if its actions are a "substantial factor" in diverting that individual from a more secure setting. The ruling reinforces a broad view of foreseeability under the substantial factor test, making it more difficult for defendants to obtain summary judgment by arguing that an intervening event, such as an escape from another facility, breaks the chain of causation. This precedent widens the net of potential liability for parties who play a material role in a chain of events leading to foreseeable types of harm.
