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Case Law Update: Negligence in Mental Health

Tedrick v. Community Resource Center, Nos. 104861 & 104876 (9-24-09) revered a case stating that the nonpatient status of decedent, who was killed by husband with history of psychiatric problems, meant that defendant mental health providers had no duty to decedent, and had not voluntarily undertaken any duty; and husband and wife’s relationship did not constitute “special relationship” which could transfer defendants’ duties of care from husband to decedent. This case will impact medical malpractice cases in Illinois.