Tieqiao (Tim) Zhang v. Emory University: Foreseeability and Special-Relationship Limits on University Liability for Student Suicide

Introduction

In Tieqiao (Tim) Zhang v. Emory University, No. 23-12365 (11th Cir. May 23, 2025), the Eleventh Circuit addressed whether Emory University and its staff could be held liable in negligence for the suicide of a minor student, Albert Liang, under Georgia law. The appellants, Albert’s parents, alleged that Emory breached duties of care—in particular through its advisor, Dr. Edmund Goode—by failing to recognize warning signs, to follow its own suicide‐prevention protocols, and to notify Albert’s parents of his mental‐health struggles. The District Court dismissed the amended complaint for failure to state a claim, and the Eleventh Circuit affirmed, holding that (1) generalized knowledge of suicide‐risk factors, without direct awareness that Albert was suicidal, is insufficient to establish foreseeability; and (2) Georgia’s special‐relationship exception to the rule that suicide is an unforeseeable intervening act was not triggered under these facts.

Summary of the Judgment

The Court of Appeals considered two main challenges:

Procedurally, whether the District Court erred by considering exhibits (an email chain and a police report) outside the pleadings without converting Emory’s motion to dismiss into one for summary judgment.
Substantively, whether the amended complaint plausibly alleged that Emory owed a duty to Albert, breached it, and proximately caused his suicide—specifically, whether Albert’s death was foreseeable under Georgia law’s “special‐relationship” exception to the general rule that suicide is an unforeseeable intervening act.

The Eleventh Circuit held:

Under the incorporation‐by‐reference doctrine, the District Court properly considered the full email exchange and police report, as both were central to the plaintiffs’ claims and undisputed in authenticity.
Georgia law requires, even in a special‐relationship context, that the defendant have direct knowledge or reasonable grounds to foresee the specific risk of suicide. General awareness of risk factors (e.g., age, demographic trends, programmatic suicide‐prevention efforts) does not meet that standard.
The amended complaint lacked factual allegations showing that Dr. Goode or Emory actually believed—or reasonably should have believed—Albert was suicidal before the automated email he sent shortly after his death.
Accordingly, the complaint failed to state a negligence claim, and the dismissal was affirmed.

Analysis

Precedents Cited

Erie R. Co. v. Tompkins (304 U.S. 64 (1938)) – Federal courts sitting in diversity must apply state substantive law, here Georgia tort law.
Maia v. City of Richmond Hill (800 S.E.2d 573 (Ga. 2017)) – Under Georgia law, suicide is ordinarily an unforeseeable intervening act, absolving a defendant of liability, except under the “special‐relationship” or “rage‐or‐frenzy” exceptions.
McAuley v. Wills (303 S.E.2d 258 (Ga. 1983)) – Foreseeability and proximate cause may be decided by the court in “plain and undisputed cases.”
Appling v. Jones (154 S.E.2d 406 (Ga. Ct. App. 1967)) – Definition of the rage‐or‐frenzy exception, not applicable here.
Huggins v. Aetna Casualty & Surety Co. (264 S.E.2d 191 (Ga. 1980)) – Discussion of Georgia’s “Good Samaritan” doctrine, which does not extend to a duty to train staff in suicide prevention.
Tellabs, Inc. v. Makor Issues & Rights, Ltd. (551 U.S. 308 (2007)) – Incorporation‐by‐reference exception at the motion‐to‐dismiss stage.
Ramirez v. Paradies Shops, LLC (69 F.4th 1213 (11th Cir. 2023)), Resnick v. AvMed, Inc. (693 F.3d 1317 (11th Cir. 2012)), Plowright v. Miami-Dade Cnty. (102 F.4th 1358 (11th Cir. 2024)) – Eleventh Circuit pleading standards in diversity cases.

Legal Reasoning

1. Procedural – Incorporation by Reference: The Court reaffirmed that a district court may consider undisputed, authentic documents central to the complaint without converting a motion to dismiss into one for summary judgment. Because the email exchange and police report were quoted or referenced in the amended complaint and were not challenged in authenticity, their consideration was proper.

2. Substantive – Foreseeability and Special Relationship: Under Georgia law, a negligent defendant is not liable for a plaintiff’s suicide—an independent intervening act—unless an exception applies:

The special‐relationship exception arises when the defendant and plaintiff share a relationship imposing an affirmative duty (e.g., hospital–patient, custodian–ward). Even then, Georgia requires direct knowledge or reasonable grounds to foresee the specific risk of suicide.
The amended complaint alleged only generalized risk factors—Albert’s age, ethnicity, male gender, relationship breakdown, homelessness—and institution-wide suicide prevention programs. It did not allege that any Emory staff member actually believed Albert was suicidal before the email sent after his death.
Because there was no plausible allegation that Dr. Goode or Emory had direct awareness of Albert’s suicidal state prior to the fatal act, the complaint failed to establish proximate cause under Georgia’s heightened foreseeability standard.

Impact

This decision reinforces the stringent requirements for suing educational institutions under Georgia law for student suicides:

Universities and their staff are not automatically subject to negligence liability simply because they operate suicide‐prevention programs or possess generalized knowledge of demographic risk factors.
Plaintiffs must allege—and ultimately prove—direct, contemporaneous knowledge or reasonable grounds to believe that the individual student was suicidal before the attempt.
Procedurally, motions to dismiss in similar cases may properly consider undisputed, central documents cited in the complaint without conversion to summary judgment.

Complex Concepts Simplified

Foreseeability: In tort law, a defendant is only liable if they could reasonably predict the harm. Under Georgia law, predicting suicide requires more than general worry about student mental health—it requires specific warning signs or admissions that the individual will harm themselves.
Suicide as an Intervening Act: Normally, a suicide is viewed as an independent event that “breaks the chain” of liability for prior negligence, unless an exception applies.
Special-Relationship Exception: Some relationships (e.g., hospital and patient, custodian and ward) impose a duty to prevent self-harm. Georgia recognizes this exception but still demands that the defendant know—or should have known—of the plaintiff’s suicidal intent.
Incorporation-by-Reference Doctrine: When a complaint relies on parts of documents, a court can consider those full documents at the pleading stage if they are central to the claims and not disputed in authenticity.

Conclusion

Tieqiao (Tim) Zhang v. Emory University affirms that under Georgia law, a university’s generalized awareness of suicide risks and existence of prevention programs do not create negligence liability for a student’s suicide absent direct knowledge or reasonable grounds to foresee that the specific student was suicidal. The Eleventh Circuit’s decision underscores both the procedural boundaries for motions to dismiss and the substantive requirement that foreseeability—especially in suicide cases—must be anchored in particularized, factual allegations of the student’s mental state prior to the fatal event.