the custodial aspect of the institutionalization — barred windows, locked doors, straitjackets and physical restraint to prevent inmates from harming themselves or others. Today, with more known about the cause and cure of mental illness, the mental hospital has become primarily a treatment facility. While maximum security units are retained, the primary emphasis is now upon therapy and rehabilitation. An attending psychiatrist's order that a particular patient be assigned to an open or closed unit represents a balance of both protection and treatment. 20 Restatement (Second) of Torts § 283B cmt. b(2); Ellis, Tort Responsibility of Mentally Disabled Persons at 1086-87; Splane, Tort Liability of the Mentally III at 156, n.19. 21 See Hobart v. Shin, 705 N.E.2d 907, 912-13 (Ill. 1998) (<HOLDING>); Cooper v. County of Florence, 385 S.E.2d 44,
holding that new york law reasonable cause standard is equivalent to fourth amendments probable cause standard holding that the person who travels as an agent of person defrauded is a victim holding mentally disabled suicide victim to reasonable person standard holding that a person is seized when a reasonable person would have believed that he was not free to leave holding that schools failure to take steps to prevent students attempted suicide was not even close to violating this outrageousness standard