Dever v. State

In Dever v. State, 29 Ill. Ct. Cl. 374 (1974), a mentally ill patient escaped the respondent hospital and inflicted severe property damage on a neighboring property owner's home. The Court found that the respondent hospital breached its duty of care to the third-party home owner by leaving the patient in an improperly assigned, unlocked ward because an attack by the patient was foreseeable: her well-documented medical record clearly evidenced her violent propensities. Id. at 376.