The issue in this case is proximate cause: Where defendant allows a voluntary mental patient to "elope" from its facility, can that defendant be liable for an assault that the patient perpetrates two years later? Given the extensive history of extreme and consistent violence the patient in this case exhibited, we answer that question in the affirmative.
On July 25, 1993, Tony Joseph, a voluntary mental patient at Manhattan Psychiatric Center (MPC), eloped from the...
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