Martin v. Smith (Majority, with Dissenting)Annotate this Case
The Supreme Court affirmed the circuit court's order granting summary judgment to Defendant, Dr. Leslie Smith, based on quasi-judicial immunity, holding that Defendant was entitled to quasi-judicial immunity because the suit sought to hold him liable for his performance of functions integral to the judicial process.
In 2011, Kenneth McFadden stabbed Virgil Brown to death in their shared apartment. At the time of the murder, McFadden was in custody of Greater Assistance to Those in Need, Inc. as part of his conditional release under Act 911 of 1989 and was serving psychiatric treatment by Dr. Smith. Plaintiff, Brown's daughter, filed this action against Dr. Smith on behalf of her father's estate, claiming that Dr. Smith's alleged failure to provide adequate treatment to McFadden rendered him liable for her father's death. The circuit court concluded that Dr. Smith was entitled to immunity because his treatment of McFadden arose solely from the conditional release order and was within the scope of that order. The Supreme Court affirmed, holding that to the extent Dr. Smith's actions fell within the scope of the court's order he was entitled to quasi-judicial immunity.