Our Team Secures Major Legal Victory in Delray Patient Elopement Case

Key Takeaways

• A Florida court denied a rehab center's motion to dismiss a wrongful death case involving an 18-year-old who died after leaving the facility

• The ruling establishes that juries, not judges, should decide whether facilities owe duties to patients who elope

• Treatment centers cannot automatically escape liability by claiming their duty ended when a patient walked away

• The decision applies when facilities failed to properly diagnose, treat, or follow protocols before elopement

• Expert evidence showing treatment failures and foreseeable harm was critical to securing this ruling

• Law360 covered this case, signaling its importance to the legal community

• This ruling gives other families facing similar circumstances a potential path to justice

RehabMalpracticeLaw.com recently secured an important victory for our clients in a lawsuit against a Florida addiction treatment center. Their 18-year-old son died after leaving the facility in a vulnerable state. The treatment center asked the court to dismiss the entire case before trial. They argued they had no legal responsibility once he walked off the property.

A Florida state court judge denied that request. The judge ruled that a jury must decide whether the facility's conduct led to this tragedy. The case will proceed to trial later this year.

This ruling does not create new statewide law. However, it establishes an important principle. Treatment centers that oversee every aspect of a patient's care cannot simply walk away from responsibility when a vulnerable patient elopes. Courts will examine what happened before the elopement. Courts will ask whether the facility's failures made harm foreseeable.

What Happened in This Case?

A Family's Trust Broken

In June 2020, our clients admitted their 18-year-old son to Caron Renaissance. They trusted the facility to provide professional treatment for his mental health and substance use disorder. He had just completed treatment elsewhere. He entered this next phase of care with hopes of recovery.

The facility controlled every aspect of his daily life. They prescribed his medications. They supervised his activities. They made treatment decisions. They held his phone and money. They restricted his contact with family.

The Elopement and Death

About three months after admission, he left the facility. He was in a vulnerable state. He had no phone. He had no money. He had no identification. The treatment center did not contact emergency authorities. They did not alert local police. They did not notify the family immediately.

Less than two days later, he was killed by a train. He was 18 years old.

The Facility's Defense Strategy

The treatment center's attorneys filed a motion for summary judgment. Summary judgment asks the court to dismiss a case before trial. It argues that even if all the plaintiff's facts are true, the defendant cannot be held liable as a matter of law.

The facility made a simple argument. Because he left on his own, and because he was legally an adult, they bore no responsibility. They owed no legal duty once he walked away. The court should dismiss the case without letting a jury hear it.

This is a common defense strategy in patient elopement cases. Facilities argue that adult patients can come and go as they please. Once they leave, the facility has no obligation to do anything.

What Did Our Legal Team Argue?

Facilities Cannot Escape Duty That Easily

Our position was direct. Addiction treatment centers that oversee every aspect of a patient's care cannot simply wash their hands of responsibility the moment a patient elopes. Especially when the patient is vulnerable, unwell, and lacks resources or support.

We argued that the facility's duty of care did not automatically end when he walked off the property. The question is whether the facility acted reasonably under the circumstances. A jury should decide that question, not a judge.

Evidence of Treatment Failures Before Elopement

We presented extensive expert evidence. Our experts reviewed the facility's medical records. They reviewed treatment notes. They reviewed the facility's own policies and protocols.

Our experts alleged that the facility failed to properly diagnose our client's son. They failed to treat his co-occurring mental health conditions appropriately. Staff members did not work together on his care plan. Communication between clinical team members broke down.

When he eloped, staff did not follow the facility's own protocols. They did not contact emergency services. They did not conduct a proper risk assessment. They did not take basic steps to locate him or ensure his safety.

Foreseeability of Harm

We argued that these failures created a foreseeable risk of harm. The facility knew or should have known that he was vulnerable. They knew he had mental health issues. They knew he lacked resources. They knew he was in an unfamiliar area without support.

A reasonably competent facility would have taken steps to prevent elopement. A reasonably competent facility would have responded differently when elopement occurred. These failures may have contributed to his death.

Under Florida law, that is a question for a jury. Not a decision for a judge on summary judgment.

What Did the Court Rule?

Denial of Summary Judgment

The judge denied the facility's motion for summary judgment. The judge found that factual disputes exist. These disputes must be weighed by a jury, not dismissed by the court.

The judge agreed that reasonable people could disagree about whether the facility met its duty of care. The judge agreed that reasonable people could disagree about whether the facility's failures caused or contributed to the death.

When reasonable disagreement exists, the case goes to trial. The jury decides the facts. The jury decides whether the facility was negligent.

What This Means Legally

This ruling keeps the case alive. Our clients will have their day in court. A jury will hear the evidence. The jury will decide whether the facility's conduct fell below the acceptable standard of care.

The ruling does not guarantee we will win at trial. It means we get the chance to present our case. It means the facility must defend its actions in front of a jury.

For families in similar situations, this ruling shows that courts may examine facility conduct more closely. Courts will not automatically dismiss cases just because a patient left the facility voluntarily.

Why Does This Matter for Other Families?

Common Assumptions About Legal Options

Many families assume they have no legal options when their loved one left a rehab facility and was harmed. They think the facility escapes liability because the patient made their own choice to leave. They think being a legal adult eliminates the facility's duty.

This case demonstrates that these assumptions may be wrong. The question is not just age. The question is not just whether the patient chose to leave. The question is whether the facility acted reasonably under all the circumstances.

What Facilities Must Consider

This ruling sends a message to treatment facilities across Florida. You cannot ignore warning signs. You cannot provide inadequate treatment. You cannot fail to follow your own protocols. Then claim you have no responsibility when a patient elopes and is harmed.

Facilities must properly assess patients. They must provide appropriate treatment. They must supervise vulnerable patients adequately. They must respond appropriately when patients elope.

If they fail in these duties, they may face liability. Even if the patient left voluntarily.

Questions This Ruling Raises for Treatment Centers

Did you properly diagnose and treat the patient? Facilities that miss mental health diagnoses or fail to address co-occurring conditions may create foreseeable risks.

Did you follow your own policies and protocols? Facilities that violate their own written procedures face serious liability questions.

Did you respond appropriately to elopement? Facilities that fail to contact authorities, assess risk, or attempt to locate vulnerable patients may be negligent.

Was the harm foreseeable? If a patient was clearly vulnerable and the facility's failures made harm predictable, liability may exist.

What Legal Hurdles Did We Overcome?

A Well-Defended Motion

Caron Renaissance is a well-known rehab center. They have experienced legal counsel. Their summary judgment motion was detailed and strongly argued.

They leaned heavily on the idea that their legal duty ended when the patient left their care. They cited cases involving competent adults who made independent decisions. They argued no facility can be responsible for what happens after discharge.

We had to overcome these arguments with evidence and legal analysis.

Months of Expert Work

We retained multiple experts. Medical experts reviewed the clinical care. They identified treatment failures. They explained how those failures departed from accepted standards.

Mental health experts reviewed the psychiatric treatment. They explained how the facility missed critical diagnoses. They showed how inadequate treatment increased vulnerability.

Treatment facility operations experts reviewed the facility's policies. They showed where staff failed to follow protocols. They explained what a reasonably competent facility would have done differently.

Careful Legal Briefing

Our legal team filed detailed opposition to the motion for summary judgment. We cited Florida law on duty of care. We cited cases involving vulnerable patients. We cited medical malpractice standards.

We showed that factual disputes existed. We showed that these disputes were material to the outcome. We showed that a jury must resolve them.

This took months of work. It required deep understanding of Florida negligence law. It required deep understanding of mental health treatment. Attorney Ryan P. Ingraham's background in insurance defense helped anticipate the facility's arguments. Attorney Susan B. Ramsey's nursing background helped identify clinical failures.

Why Did Law360 Cover This Case?

National Legal Publication Recognition

Law360 is a national legal publication. Attorneys, judges, and law professionals across the country read it. Law360 highlights important motions, rulings, and legal trends.

Law360 covered this case in an article published July 9, 2025. You can read it here: https://www.law360.com/florida/articles/2362349

The fact that Law360 covered this ruling signals its importance. While this case has not changed Florida law yet, it involves real legal and factual questions that the legal community is watching.

What Makes This Case Noteworthy

Most summary judgment rulings do not receive national attention. Law360 chose to cover this case because it addresses an important issue. Treatment facilities increasingly argue they have no duty once patients leave their care. Courts must decide whether to accept this argument.

This ruling suggests that courts will not simply accept it. Courts will look at what happened before the patient left. Courts will examine whether facilities met their duties while the patient was in their care.

This matters for the entire addiction treatment industry. It matters for families seeking accountability.

What Should You Do If This Happened to Your Family?

Do Not Assume You Have No Case

If your loved one was harmed or died after leaving a rehab or behavioral health center, do not assume the door is closed. Do not assume the facility has no liability because your loved one was an adult. Do not assume voluntary elopement eliminates all responsibility.

Every case is different. Not every situation leads to a lawsuit. But this case shows that even when the odds seem against you, a path forward may exist.

Gather Evidence Immediately

If you suspect negligence, act quickly. Obtain medical records from the facility. Request incident reports. Document what you know about the treatment your loved one received.

Write down what facility staff told you. Save emails and text messages. Preserve any voicemails or written communications.

Evidence disappears over time. Staff members leave. Memories fade. Medical records may be altered or destroyed. Early action preserves your rights.

Contact Specialized Legal Representation

Patient elopement cases are complex. They require knowledge of Florida negligence law. They require understanding of medical and mental health treatment standards. They require experience with facility operations and protocols.

General personal injury attorneys may not recognize the legal issues these cases present. They may not know how to overcome facility defenses. They may not have access to the right experts.

RehabMalpracticeLaw.com focuses exclusively on rehab and treatment facility malpractice. We secured this ruling. We know how to prove these cases. We know how to counter facility defenses.

Frequently Asked Questions

Does this ruling mean all elopement cases will go to trial now?

No. Each case depends on its specific facts. This ruling establishes that courts will not automatically dismiss elopement cases. However, families still must present evidence of treatment failures and foreseeable harm. Not every elopement case will survive summary judgment.

What if my loved one was older than 18?

Age alone does not determine liability. The question is whether the facility provided proper care while the patient was in their custody. The question is whether they responded appropriately to elopement. Adult patients can still be vulnerable patients deserving of protection.

What counts as proper response to elopement?

This depends on the patient's condition and circumstances. Generally, facilities should conduct risk assessments. They should contact family members. They should contact local authorities if the patient poses a danger to themselves or others. They should document their response. Facilities that ignore elopements entirely may face liability.

How long do we have to file a lawsuit?

Florida Statute § 95.11(4)(b) generally requires medical malpractice claims to be filed within two years from the date of injury or death. Wrongful death claims must be filed within two years of the date of death under Florida Statute § 95.11(4)(d). These deadlines are strict. Missing them permanently bars your claim.

What if the facility says they told us our loved one could leave at any time?

Being free to leave does not eliminate the facility's duty to provide proper care while the patient is there. It does not eliminate the duty to respond appropriately when a vulnerable patient elopes. What they told you about voluntary status may not be relevant to whether they were negligent.

Will our case definitely go to trial if we file?

Not necessarily. Many cases settle before trial. This ruling simply means the case survived a motion to dismiss. Whether your specific case goes to trial depends on many factors including the strength of the evidence and the facility's willingness to settle.

How much does it cost to pursue a case like this?

We handle these cases on a contingency fee basis. You pay no attorney fees unless we recover compensation. We advance all case costs including expert fees. Initial consultations are free.

Get Help After a Loved One Was Harmed Following Rehab Elopement

If your loved one was harmed or died after leaving a Florida rehab or behavioral health center, contact RehabMalpracticeLaw.com today. You may have legal options even if the facility claims they have no responsibility.

We offer free, confidential consultations. We will review what happened. We will tell you honestly whether we believe you have a case. You are not obligated to hire us just by talking with us.

Time matters. Evidence disappears. Florida law sets strict deadlines. Contact us today to protect your rights and get the answers you deserve.

Justice is not always easy. But this case shows it is possible.