Woods v. Mont. State Hosp.
Annotate this CaseTwelve days after Justin Schiller was involuntarily committed to the Montana State Hospital (MSH), Schiller was released. A few months later, Schiller killed his former girlfriend, Catherine Woods, and then himself. Catherine’s parents filed a complaint alleging that MSH had a statutory duty to warn Catherine of the risk of violent behavior by Schiller. The district court granted summary judgment in favor of the State and MSH, concluding that MSH had no duty to warn Catherine or take precautions for her protection because Schiller never communicated any specific threat of violence against Catherine during his commitment. The Supreme Court affirmed, holding that because no actual, specific threat was communicated in this case, the duty to warn was not triggered.
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