ProfessorMelissa A. Hale
CaseCast™ – "What you need to know"
Brief Fact Summary. Mcquire (Plaintiff), a registered nurse, was hired to care for Almy (Defendant), an insane person. During a violent attack, Defendant stuck Plaintiff with the leg of a low-boy (a piece of furniture). Plaintiff brought suit against Defendant for assault and battery.
Synopsis of Rule of Law. An insane person is liable for his intentional torts.
Under the Sponatski rule, a suicide following a work-connected injury is compensable only where there follows as the direct result of a physical injury an insanity of such violence as to cause the victim to take his own life through an uncontrollable impulse or in a delirium of frenzy without conscious volition to produce death, without having knowledge of the physical consequences of the act'.View Full Point of Law
Issue. Is Defendant, an insane person, liable for assault and battery?
Held. Yes. Judgment for Plaintiff on the verdict.
* Courts almost invariably hold an insane person liable for his torts. Where an insane person by his act does intentional damage to the person or property of another he is liable for that damage in the same circumstance in which a normal person would be liable.
* The law will not inquire further into an insane person’s peculiar mental condition with a view to excusing him if it should appear that delusion or other consequence of his affliction has caused him to entertain that intent or that a normal person would not have entertained it. In this case, the jury could have found that Defendant was capable of entertaining, and that she did entertain, an intent to strike and to injure Plaintiff and that Defendant acted upon that intent.
Discussion. An insane person will be liable for his or her torts. Previous rulings involving insanity have prevented liability for certain intentional torts such as defamation and deceit largely because they require a malicious intent. In those cases, the law holds that such intent must be shown.