Scottsdale Ins. Co. v. Nat H. Sandler 381 Fed. Appx. 554 (6th Cir. Ky. 2010). A doctor employed by a mental health clinic prescribed antidepressants to a former patient and social acquaintance, after advising the former patient not to seek help at the clinic. The former patient complied with the doctor’s advice. The patient subsequently committed suicide, and his estate brought suit against the doctor and the clinic. In an action for declaratory judgment, Richardson Law Group successfully argued at the trial court the clinic’s insurance policy did not cover the doctor’s treatment of a patient outside the scope of his employment with the clinic. Richardson Law Group’s advocacy persuaded the appellate court to affirm on the basis that the doctor was not acting in furtherance of his employer’s business when he advised the former patient to seek treatment elsewhere and due to the fact that the decedent never became a patient of the clinic.
