Radford Barnes v. Emmett O. Dale

JONES, JUSTICE. Dr. Radford Barnes, Dr. Waters Paul, and James Harpole (State of Alabama employees) appeal from a judgment in favor of Emmett
O. Dale, as administrator of the estate of Patrick F. Dale, deceased. The administrator filed a wrongful death suit against
the appellants for the allegedly negligent and wanton treatment and release of Douglas Edward Griffin from the substance abuse
unit at Bryce Hospital--a mental health facility owned and operated by the State of Alabama. Seventy-two days after his discharge
from Bryce, Griffin shot and killed Patrick Dale. The ultimate issue here presented is whether the trial court erred in rejecting
the defendants' "qualified immunity" defense. We hold that it did so err; we reverse the judgment and render judgment for
the defendants. (We also address, preliminarily, whether the appellants preserved the "immunity" issue for appellate review.)
The facts of this civil appeal and its criminal predecessor are complex and detailed. (The record of Griffin's criminal trial
was made a part of the record in this case.) 1 We will not undertake an exhaustive review of Douglas Griffin's troubled
life before his commitment to Bryce Hospital, other than to note that he had a long history of alcoholism. The issues raised
on appeal, however, do require a factual review of Griffin's admission, treatment, and discharge from Bryce; the procedural
steps of the trial; and the professional background and employment of each of the appellants. It is to these areas that we
now turn our attention.