IL: Appellate Court Holds that Mental Health Providers Can Be Liable for the Suicide of Outpatient Mental Health Clients

In a recent case, an Illinois appellate court held that mental health providers can be held liable for the suicide of their patients, even if they are treating them on an outpatient basis.  O’Donnell v. Bailey & Assocs. Counseling, 2023 IL App (1st) 221736, ¶ 3, ___ N.E.3d ___ (2023) (“[A] mental healthcare provider can be held liable when treating an outpatient client for a suicide that is proximately caused by the provider's failure to act within the standard of care.”).