City of Richmond Hill v. MaiaAnnotate this Case
Following the suicide death of her 14-year-old daughter, Appellee Laura Lane Maia sued the mayor and city council of the City of Richmond Hill (collectively, “the City”) and Douglas Sahlberg, individually and in his capacity as an officer with the Richmond Hill Police Department (collectively “Appellants”), alleging wrongful death and associated claims. Appellee’s daughter, Sydney Sanders, attempted suicide by cutting herself in the neck, chest, and abdomen, and she was subsequently taken to the hospital for medical treatment. Officers with the Richmond Hill Police Department (“RHPD”), including Officer Sahlberg, responded to the hospital to investigate, and Sanders’s injuries were photographed by the officers. Sahlberg accessed those photographs on his work computer and showed them to his daughter, K.S., who was a classmate of Sanders; shortly thereafter, K.S. was seen using her cell phone to show the images to other classmates. Sanders was distraught and mortified to discover that the photographs had been shared. In her complaint, Appellee averred (inter alia): that Salhberg had a duty to keep the injury photographs confidential; that he had breached that duty; that Sahlberg should have known that the publication of the photographs created a reasonable apprehension that Sanders would further harm herself; and that Sanders’s death was caused by Sahlberg’s negligent conduct. Appellants moved for summary judgment, asserting that Appellee could not demonstrate causation because, under Georgia law, suicide was generally an independent act which breaks the chain of causation from the events preceding the death. The trial court denied the motion with a one-page order and granted a certificate of immediate review. A divided Court of Appeals affirmed, concluding that, because “Sanders’s suicide was a reasonably foreseeable consequence of Sahlberg’s negligent conduct, [Sanders’s] act of suicide was not an intervening act that would preclude Sahlberg’s breach of duty from constituting the proximate cause of that injury.” The Supreme Court concluded Appellee could not demonstrate proximate cause and therefore reversed the Court of Appeals.