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Landmark Cases

Case Name: Venkataramana NAIDU v. Ann D. LAIRD

Date, Location, Cite: 1988 DE
Del Supr. 539 A.2d 1064
Del Supreme Court

Dr. Naidu treated Hilton Putney at DE State Hospital. 5 1/2 months after discharge, Putney rammed car of Mr. Laird, killed him. found Not Guilty by reason of Insanity (NGI). Mrs. Laird sued state hospital for negligent release, won $1,400,000. Experts testified both ways on "should have committed." Court said decision was jury's; also, time by itself does NOT preclude proximate cause. Dept of Mental Health as an agency was excluded by sovereign immunity. Putney had 18 prior hospitalizations with violent behavior, had rammed others with cars while psychotic, had been treated with po Navane every time, never took it post hospital.