Brief Fact Summary. Plaintiff was employed as a caregiver for Defendant, a mentally ill but physically fit woman. During one of Plaintiff’s shifts, Defendant caused a loud disturbance and told Plaintiff she would kill her if she entered her room. Plaintiff entered the room anyway, was physically attacked by Defendant, and sued for assault and battery.
Synopsis of Rule of Law. The insane are liable for their torts to the same extent as the sane, except for certain torts requiring malice of which they are incapable.
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. Did the trial court err in refusing to direct a verdict for Plaintiff for assault and battery because Defendant was insane when she attacked Plaintiff?
Held. No. The verdict was upheld and the award sustained.
* In order to be liable for intentionally damaging another, an insane person must have been capable of the same level of intent and have possessed the same level of intent as would give rise to liability for a sane person.
Discussion. Much like [Garratt v. Dailey, 46 Wash.2d 197, 279 P.2d 1091 (Wash. 1955)] held with respect to children, the Court in this case declines to carve out a specific exception to general conceptions of intent for the insane. Rather, the Court applies general standards of intent to the insane, with the caveat that insanity could preclude one’s capacity to intend certain types of actions in certain circumstances.