Insufficient Expert Causation Testimony Links Suicide to Failure to Hospitalize

Finding insufficient expert testimony on causation in fact, the Texas Supreme Court Feb. 1 reversed a judgment for the family of a woman who committed suicide three days after a psychiatrist determined that she did not need inpatient hospital care (Rodriguez-Escobar v. Goss, Tex., 10-0511, 2/1/13).

Testimony that the plaintiff’s expert, Dr. Mary Iva Anderson, a board-certified psychiatrist, did not think decedent Beverly Goss would have been able to shoot herself while hospitalized, is not evidence that hospitalization probably would have prevented her from doing so after she was released, the state top court said.

Whereas Anderson ...