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Psychiatric Malpractice - Texas Supreme Court


To determine whether the actions of the defendants in Dowell proximately caused Dowell's suicide we analyzed both factors of the cause-in-fact element of proximate cause: whether the actions were a substantial factor in bringing about the suicide and whether, but for the actions, the suicide would not have occurred. In this case we need only consider the but-for factor. That is, we consider whether the evidence is legally sufficient to support the finding that absent the negligence of Dr. Rodriguez-Escobar-but for his negligence-Goss would not have committed suicide.

Rodriguez-Escobar v. Goss (Texas Supreme Court 2013)

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