Garrett v. Lynch, ARNP, Sarasota Pain Management, et al.

The Second DCA affirmed summary judgment for an ARNP and her employer pain clinic in a medical malpractice wrongful death action, holding that the provider-patient duty of care terminated when the patient voluntarily discharged the defendants, and that no post-discharge duty arose under section 766.102 or Florida common law. The court further held proximate cause was severed by the patient's own refusal of substitute medications, his consultation with five-plus intervening physicians, and the passage of more than ninety days before his suicide. For civil practitioners the opinion provides clear authority that a voluntarily initiated discharge ends the relational duty in healthcare malpractice and that robust intervening patient conduct defeats proximate causation at the summary judgment stage.

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