Utah Supreme Court rules medical staff had duty to children in David Ragsdale case
SALT LAKE CITY — The Utah Supreme Court ruled Tuesday that the medical staff treating a man who shot and killed his wife had a duty to the couple's children.
The unanimous decision reversed an earlier dismissal of the David Ragsdale case by a trial judge.
Ragsdale pleaded guilty to aggravated murder in the Jan. 6, 2008, shooting that left Kristy Ragsdale dead with 13 gunshot wounds in a Lehi church parking lot. He was sentenced to life in prison without parole.
It was determined that he was taking various medications at the time, including Concerta, pregnenolone, testosterone, Valium and the antidepressants Doxepin and Paxil. But blood toxicology reports showed David Ragsdale was within the prescribed ranges for all his medications and found no traces of any illicit substances at the time of the shooting.
A court-appointed guardian for the Ragsdales' two children — then ages 3 and 6 — filed a lawsuit against those treating him, arguing that it was negligence on the part of those prescribing medications to David Ragsdale that prompted his violent acts. The lawsuit named the nurse practitioner who wrote David Ragsdale's prescriptions, her consulting physician, the medical clinic where the two worked and various other employees of the clinic.
Ragsdale reinforced the belief that the medications altered his behavior at the time of his sentencing: "I want you to know that I am confident I would not have taken Kristy's life had I not been on the medications I was on. But that being said, I take full responsibility for my actions," he said then.
Attorneys for the clinic and its employees argued for dismissal of the lawsuit on the grounds that there was no duty to the children because they were third parties who were not directly involved in the patient-provider relationship. Third District Judge Denise Lindberg agreed, dismissing the lawsuit and prompting the children's guardian, William Jeffs, to appeal the decision to the state's high court.
In a ruling written by Justice Thomas Lee, the Utah Supreme Court found that there was a duty on the part of health care providers to the children and reversed the dismissal.
"Health care providers perform a societal function of undoubted social utility," Lee said. "But they are not entitled to an elevated status … that would categorically immunize them from liability when their negligent prescriptions cause physical injury to non-patients."
Attorneys for nurse practitioner Trina West, Dr. Hugo Rodier and Pioneer Comprehensive Medical Clinic argued that reversing the ruling would have a chilling effect on health care providers who would fear treating patients with mental health issues. They also questioned whether a duty to third parties would conflict with the loyalty and confidentiality owed to a patient.
But the high court decided that this case was different from other, previous cases involving liability for those who failed to control the actions of a patient. In those cases, the health care providers were not found responsible for the actions of their patients.
"(Those cases) all stand for the proposition that a health care provider is not required to control its patients' independent conduct," Lee wrote. "They do not support defendants' view that a health care provider may—with immunity from liability to any non-patient—negligently prescribe medication that affirmatively causes a patient to injure non-patients."
The lawsuit will now return to the trial court.
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