Sinai Hospital had ‘duty’ to warn woman before releasing patient who killed her, court says

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A wrongful-death lawsuit brought by the children of a woman who was killed by her husband after his release from psychiatric treatment at Sinai Hospital of Baltimore can proceed, the Maryland Appellate Court ruled Friday.

A three-judge Appellate Court panel ruled that the Baltimore City Circuit Court was wrong to dismiss a lawsuit brought by the two sons of Kelly Ann Caples and Jeffrey Caples, who expressed homicidal ideation on the day he was discharged from Sinai Hospital.

Jeffrey Caples is serving life in prison for murdering Kelly at their Hampstead home in December 2020, eight days after his release from the hospital.

The court ruled that this case was clearly distinguishable from others in which courts ruled for the defendant institutions.

“Decedent was a ‘readily identifiable’ potential victim within the ‘zone of danger’ such that Sinai had a duty to warn her of Caples’ homicidal ideation prior to her death,” Appellate Judge Laura Ripken wrote.

Ripken was joined by Judge Terrence Zic and Senior Judge James Eyler, who was specially assigned.

“The family is obviously happy with the appellate court’s decision,” said Kevin Sullivan, of Sullivan Law in Baltimore, who represented the plaintiffs. “We think they got it right … We look forward to continuing to prosecute the case and get in front of a jury.”

Sinai was represented by Greg Garrett of Tydings & Rosenberg in Baltimore, who declined to comment.

Jeffrey Caples, the opinion states, went to the emergency room at the Johns Hopkins Hospital because of suicidal thoughts on Nov. 17, 2020, and was soon admitted voluntarily to Sinai’s inpatient psychiatric unit.

He had been medicated for recent episodes of aggression and informed hospital staff of suicidal and homicidal ideation, including on the day he was released, according to court documents. He said he had the desire to kill “anyone who comes close.”

The Caples’ two sons filed a wrongful-death lawsuit in Baltimore City Circuit Court in April 2024, alleging that Sinai’s negligence caused Kelly’s death. They argued the hospital had a duty to warn her and the son that lived with them of his violent statements.

The hospital soon filed a motion to dismiss, arguing it was immune because of a state law that prevents lawsuits against mental healthcare providers in certain circumstances. The law protects providers unless they knew of the patient’s “propensity for violence” and the patient indicated their “intention to inflict imminent physical injury upon a specified victim or group of victims.”

The trial court agreed with the hospital and threw out the lawsuit.

The Maryland Appellate Court disagreed, allowing the case to move toward trial. It identified four cases in which courts had declined to hold the mental healthcare providers liable because the damages or violence were “unforeseeable” — and found that the Caples case was clearly different.

A jury could reasonably find that Caples had an “intention to inflict imminent physical injury” and that his conduct demonstrated a “propensity for violence,” Ripken wrote.

“(T)wo people would obviously fit into the category of people who would come close to Caples: Decedent and an adult son,” she wrote.

“Thus, Decedent and the adult son were ‘readily identifiable’ potential targets such that Sinai had a duty to warn them of Caples’ homicidal ideation expressed as recently as the morning of discharge because their identities were known in advance of the harm inflicted.”