What is the duty of care owed to a psychiatrist who treats a patient on an outpatient basis?

In diagnosing and treating patients, doctors must exercise the reasonable degree of skill, knowledge and care ordinarily exercised by doctors under similar circumstances in their professional community. The standard of skill, knowledge and care prevailing in a medical community is ordinarily a matter within an expert's knowledge. Expert opinion, therefore, is required to determine the probability of negligence where a medical process is not a matter of common knowledge. (Folk v. Kilk (1975) 53 Cal.App.3d 176, 185, [9 Cal.App.4th 106] 126 Cal.Rptr. 172.) Diagnosis, treatment and care of a schizophrenic and suicidal psychiatric patient, and the standard of care prevailing in the medical community for such patients, are not matters of common knowledge.

In Bellah v. Greenson (1978) 81 Cal.App.3d 614, 146 Cal.Rptr. 535, the appellate court applied the long-established duty of care that doctors owe to patients to psychiatrists who treat patients on an outpatient basis. In Bellah, two years after plaintiffs' daughter committed suicide, plaintiffs brought a wrongful death action against a psychiatrist who had been treating her on an outpatient basis. Plaintiffs alleged the

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