Saunders v. Tisher, 2006 ME 94

Summary

The Maine Supreme Judicial Court affirmed dismissal of Kristopher T. Saunders's claims against psychiatrist Paul Tisher under M.R. Civ. P. 12(b)(6). The court held that claims arising from Tisher's alleged misuse of the involuntary commitment process were subject to the Maine Health Security Act and its three-year statute of limitations. Two justices dissented, concluding that the alleged retaliatory conduct could support civil-rights, emotional-distress, or wrongful-use-of-civil-process claims outside the MHSA.

Holdings

1. Claims arising from a psychiatrist's actions in determining whether a person should be involuntarily committed and admitted for mental-health treatment are actions arising from the provision of health care services and fall within the broad scope of the Maine Health Security Act, even when pleaded as civil-rights or intentional- or negligent-emotional-distress claims.
2. The MHSA's three-year statute of limitations barred Saunders's claims because the causes of action accrued in February 1998 and the complaint was not filed until February 2004.
3. Dismissal under Rule 12(b)(6) was proper when the complaint's allegations, accepted as true and viewed favorably to the plaintiff, established that the claims were MHSA claims filed outside the statutory limitations period.

Questions Presented

1. Whether claims styled as civil-rights and emotional-distress claims based on a psychiatrist's alleged misuse of the involuntary-commitment process arise from the provision of health care services and therefore fall within the Maine Health Security Act.
2. Whether the Maine Health Security Act's three-year statute of limitations barred Saunders's claims when the alleged commitment occurred in February 1998 and the complaint was filed in February 2004.
3. Whether dismissal under Maine Rule of Civil Procedure 12(b)(6) was proper based on the statute of limitations apparent from the face of the complaint.

Disposition

affirmed