CT Adopts Duty-to-Warn Rule After Branford Dentist Killed His 21-Year-Old Ex-Girlfriend

Caroline Ashworth was about eighteen when she met Michael Mollow. He was about fifty-seven. They started seeing each other in the winter of 2019, and for the next three years he paid her rent until he stopped paying it, controlled where she went and who she talked to, and cut off her phone service when he wanted to make a point. They bought a truck together, for her to drive, and he quietly kept the title in his own name.

On August 22, 2022, Caroline moved out and drove that truck to Alabama to stay with her grandmother.

The truck had a GPS tracker on it. Mollow had told the Branford police about the tracker himself a week earlier, when he reported the truck stolen. In the same conversation he mentioned the unsecured firearms in his house. Officers had been to that address more than once that month. Caroline had told them he choked her. She had told them he threatened to shoot her.

She left on a Monday. By the small hours of Tuesday morning, Mollow was in a hospital emergency room telling the staff he was emotionally distraught, that Caroline had ended the relationship, and that he was having homicidal thoughts about her specifically. He said he was afraid of what he would do if she came back to Connecticut. He said he was drinking, taking street Xanax, not sleeping. He said he owned firearms and had a pistol permit. He said he did not feel safe outside a hospital.

The emergency physician wrote it down almost verbatim — homicidal ideation toward the ex-girlfriend, depression, insomnia, poor appetite — and signed a certificate committing Mollow involuntarily for fifteen days.

Hospital staff called the Branford police and gave them Caroline’s cell number. An officer tried it. It rang through, and there was no voicemail to leave. He marked the file inactive.

The next day Mollow was transferred to a psychiatric hospital in Westport, run by SVMC Holdings. His transfer records described anger, thoughts of hurting his ex-girlfriend, a tendency toward obsessive thinking. On admission he repeated it plainly: he was there because he had thoughts of harming or killing Caroline, and he wanted medication to stop the intrusive thoughts.

Two days later, the attending psychiatrist discharged him. Eleven days remained on the fifteen-day certificate. The plan was to follow up with his primary care doctor and see a social worker in five days. No supervision, no monitoring, no conditions. Nobody called Caroline. Nobody called the police.

The following evening, Mollow pulled up the tracker, followed her truck to a condominium parking lot in Wethersfield, and found Caroline sitting in it. He shot her three times and killed her. Then he killed himself.

The case her mother almost couldn’t bring

Caroline’s mother, Angela Ashworth, sued the hospital as administratrix of her daughter’s estate. A judge dismissed the case before a single deposition — not because the facts were weak, but because of a rule that had nothing to do with Caroline at all.

In Connecticut, only a patient can sue a doctor or hospital over medical care. And the person who gets killed is, by definition, not the patient. For decades, that rule quietly ended cases like this one before they started.

On August 4, 2026, the Connecticut Supreme Court changed that.

What the court actually decided

The court split the family’s complaint in half, and the split is the whole thing.

Second-guessing the medicine is still off limits. Should the doctors have dug harder into his drinking? Was his medication handled right? Was the risk assessment thorough enough? Those are criticisms of a doctor’s professional judgment, and someone who was never the patient still can’t raise them.

But once the hospital already knows a specific person is in danger, what happens next is common sense. Pick up the phone. Call the police. Don’t let him walk out the door with eleven days left on the hold. You don’t need a medical degree to judge whether that was reasonable — so the victim’s family can bring that claim.

The failure to warn her, the failure to keep control of him, the decision to cut the hospitalization short: all of that is going back to court.

The limits

The court kept this narrow on purpose.

  • The hospital has to already know. This isn’t about predicting who might turn violent someday — the court was blunt that those predictions are unreliable. The duty kicks in only when the providers have already concluded this patient is dangerous.
  • The person has to be identifiable. A vague worry that a patient might hurt somebody isn’t enough. There has to be a her.
  • Nobody has to be locked up who otherwise wouldn’t be. Hospitals aren’t required to hold people the law doesn’t let them hold.
  • Warning isn’t the only option. The duty is to take reasonable steps. Sometimes that’s a call to her, sometimes to the police, sometimes it’s simply not discharging the patient yet. A jury decides whether what was done was enough.
  • This case involved a psychiatrist. Whether the same rule reaches psychologists, therapists, social workers, and counselors is a fight for another day.

The hospital also argued she already knew he was dangerous — she’d called the police on him before — so a warning would have changed nothing. The court rejected that. Knowing your ex has a history is not the same as knowing he just told doctors he wants to kill you and is being released tomorrow.

Why this matters beyond one case

Domestic violence homicides tend to follow the same sequence. She leaves. He escalates. And somewhere in the middle there is a professional who knew, and said nothing.

Connecticut law now says that silence can cost you.

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