Mississippi State Hospital v. Rena Wood
Annotate this Case
Download PDF
IN THE COURT OF APPEALS
OF THE
STATE OF MISSISSIPPI
NO. 2001-CA-00588-COA
MISSISSIPPI STATE HOSPITAL
v.
RENA WOOD
DATE OF TRIAL COURT
JUDGMENT:
TRIAL JUDGE:
COURT FROM WHICH APPEALED:
ATTORNEYS FOR APPELLANT:
ATTORNEY FOR APPELLEE:
NATURE OF THE CASE:
TRIAL COURT DISPOSITION:
APPELLANT
APPELLEE
03/06/2001
HON. JOHN T. KITCHENS
RANKIN COUNTY CIRCUIT COURT
JAMES P. STREETMAN III
STEFFANIE ANNE GRAVES
JOHN W. CHAPMAN
CIVIL - MEDICAL MALPRACTICE
JUDGMENT IN FAVOR OF RENA WOOD AS
WRONGFUL DEATH BENEFICIARY FOR HER
DAUGHTER, APRIL WOOD, IN THE AMOUNT OF $50,
000.
AFFIRMED - 8/6/2002
DISPOSITION:
MOTION FOR REHEARING FILED:
CERTIORARI FILED:
MANDATE ISSUED:
8/27/2002
BEFORE McMILLIN, C.J., LEE, AND BRANTLEY, JJ.
McMILLIN, C.J., FOR THE COURT:
¶1. Rena Wood filed a wrongful death action against the Mississippi State Hospital (MSH), claiming that
the hospital violated the standard of care in providing in-patient psychiatric treatment to her nineteen-year
old daughter, April Wood, and that this sub-standard care was a proximate contributing cause to April
Wood's death by suicide. The case was tried without jury before the Circuit Court of Rankin County and
the court entered judgment in favor of Wood, assessing damages at $50,000. MSH has appealed the
judgment, claiming that a determination of liability on the part of MSH is against the overwhelming weight of
the evidence. Concluding that, under the applicable standard of review, there is evidentiary support for the
judgment as entered by the trial court, we affirm the judgment.
I.
Facts
¶2. It is unhelpful to repeat in substantial detail the body of evidence presented at trial regarding the
unfortunate circumstances that led to young April Wood's hospitalization and ultimate death by suicide while
a patient at MSH. It is sufficient to say that there was uncontradicted proof of incidents of substance abuse,
multiple unsuccessful suicide attempts, a history of mental depression, and prior hospitalizations to attempt
to deal with these problems. Ultimately, April Wood submitted to a voluntary commitment to MSH and
was diagnosed with the primary problem of polysubstance drug dependency and a secondary diagnosis of
depression. Based on initial evaluations, MSH personnel determined that April Wood's chemical
dependency was the more serious problem and began a course of treatment designed primarily to deal with
that aspect of her condition. After discovery of the fact that Wood had committed a hospital rule infraction
by smoking a marijuana cigarette, she was placed on a form of restriction that involved isolation. At some
point during her prescribed period of isolation, she was informed that it was to be extended because of
subsequent violations of patient rules. Shortly after that, she was discovered to have caused her own death
by hanging.
¶3. Evidence was presented that MSH, in formulating a course of treatment and in evaluating her for
possible suicide risk, had relied primarily on the history related by the patient and on her own
representations that she was not contemplating such a course. No effort was made to obtain additional
medical history from the patient's mother or other family member. Though MSH contended that the
involuntary isolation procedure was intended to be therapeutic in effect, the plaintiff presented writings by
the patient made before her death indicating that she felt it was a form of punishment, causing her to become
more depressed.
¶4. At trial, Wood presented the expert testimony of Dr. Wood Coleman Hiatt, a practicing psychiatrist and
former faculty member at the University of Mississippi Medical School, who expressed the view that the
course of treatment undertaken by MSH violated the standard of care for a patient presenting the
psychological symptoms of April Wood. Dr. Hiatt further offered his expert opinion that this violation of the
standard of care was a proximate contributing cause to April Wood's ultimate suicide while a patient at the
hospital. In particular, Dr. Hiatt offered the view that MSH personnel had erred in treating her substance
abuse problems as the primary focus when she was exhibiting signs of severe depression and had a history
of suicide attempts. Dr. Hiatt observed that, had hospital personnel consulted with April Wood's mother,
she would have related to them many of the statements and actions taken by Wood in the time leading up to
her hospitalization that would have plainly demonstrated the depth of her depression; however, he noted
that no such effort was undertaken in determining a diagnosis and course of treatment. Additionally, Dr.
Hiatt observed that Wood had indicated to hospital personnel that she had determined a way to resolve her
problems, which should have been understood as an indication that she was seriously contemplating a
suicide effort. Finally, Dr. Hiatt expressed the view that the somewhat punitive action of isolating Wood
without placing her under some sort of frequent observation in the nature of a "suicide watch" was an
inappropriate course of treatment for a person in Wood's psychological state.
¶5. MSH, in defense, presented a number of witnesses who were involved in the diagnosis and treatment of
Wood in the time leading up to her suicide. Included among these witnesses was Dr. Alexis Polles, who
was the principal treating physician for Wood. Dr. Polles testified in some detail regarding the actions taken
in regard to properly diagnosing and treating Wood and defended the decisions made by MSH personnel,
including the decision not to place Wood under suicide watch, testifying that the symptoms exhibited by
Wood did not warrant such an action. MSH did not present opinion evidence from an expert in the field
who was not directly involved in the actual treatment of Wood who might have offered an independent, and
possibly different view from that of Dr. Hiatt, as to whether the various decisions on care were within the
standard of care for health care providers offering the type of treatment extended to April Wood.
¶6. Based upon this conflicting evidence regarding whether the applicable standard of care was violated, the
trial court found the evidence offered by Dr. Hiatt compelling and determined that there had been, in fact, a
violation of the standard of care which had been a proximate contributing cause to Wood's suicide. He
entered judgment in favor of Rena Wood as wrongful death beneficiary for her daughter, April Wood, in the
amount of $50,000. This appeal ensued.
II.
Discussion
¶7. This case was brought under this state's Tort Claims Act, which permits negligence actions against state
agencies under certain conditions that include the requirement that, if the matter comes to trial, it will be
conducted as a bench trial. Simpson v. City of Pickens, 761 So. 2d 855, 860 (¶15) (Miss. 2000). In that
situation, the trial court sits as finder of fact and, when the court's factual determinations are challenged on
appeal, the reviewing court must consider the entire record and is obligated to affirm where there is
substantial evidence in the record to support the trial court's findings. Ezell v. Williams, 724 So.2d 396,
397 (Miss. 1998). We find that Dr. Hiatt's expert testimony was competent on the question of the relevant
standard of care that was before the court for decision and, though his opinion was sharply contradicted by
competing opinion evidence presented by the defense, Dr. Hiatt was not substantially impeached nor was
his expertise or credibility cast into doubt through cross-examination or any of the other recognized
methods of impeaching the effectiveness of a witness. The trial court, as has long been recognized, observes
the witnesses first hand and is in the best position to assess the persuasiveness of a witness and to decide
what weight to afford that witness's testimony. Amiker v. Drugs For Less, Inc., 796 So. 2d 942, 947
(¶16) (Miss. 2000).
¶8. In this appeal, MSH, other than arguing for the credibility and persuasive power of its own witnesses,
points to nothing of note in the record that would suggest that the trial court was manifestly in error in its
decision to accept the view of Dr. Hiatt as to (a) the standard of care reasonably to be expected from an
organization providing in-patient psychiatric care to a person in the situation in which April Wood found
herself and (b) his view, expressed in direct testimony and persistently defended during cross-examination,
that MSH had violated that standard of care in this case in a manner that substantially increased the
likelihood that April Wood would have both the opportunity and a compelling psychological impulse to do
harm to herself.
¶9. Based on our limited standard of review, we find that there is, beyond question, substantial evidence in
the record to support the trial court's factual determination establishing both the standard of care and its
violation by MSH. In that circumstance, it is the duty of this Court to affirm the judgment of the trial court.
¶10. THE JUDGMENT OF THE CIRCUIT COURT OF RANKIN COUNTY IS AFFIRMED.
ALL COSTS OF THIS APPEAL ARE ASSESSED TO THE APPELLANT.
KING AND SOUTHWICK, P.JJ., BRIDGES, THOMAS, LEE, IRVING, MYERS,
CHANDLER AND BRANTLEY, JJ., CONCUR.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.