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Rehab is NOT a JAIL!
Rehab had no right to hold your mother if she was competent to make her own decision. They can only warn and advise, and they almost always make thorough notes that they have done so.
I am terribly sorry for your loss. This is a great tragedy that will serve, by your posting it here, to warn all seeing it what can happen.
Do know that your mother may have been overcome by smoke to the extent that she never really understood a fire was happening until it was far too late. I hope that was the case for you. This happens often to even well and able people.
Your mother may have been asked to sign a AMA (against medical advice) form in rehab. Do you know that is the case. They usually ask for such a thing when it is their opinion that a person is leaving who may be endangering themselves. However, there is no stipulation by law that a person MUST sign the AMA. Really, as I said, this isn't a jail.
Now, if your mother was not competent at the time she left you should discuss this with an attorney.
However, know that few such cases are taken on contingency.
As Igloo once said here, the truth is that when someone is elderly there is little recourse or recompense under the law.
I am so very sorry for this loss. Often in loss we wish to be angry and to blame so that we don't have to enter the dark woods of grieving. It has to be heartbreaking. Please don't blame yourself. There was nothing you can do when elders take it in their own minds to leave when they needed further help. And to be with her 24/7 wasn't the option; it would have only enabled her bad choice. Your mom make a bad choice that had a tragic outcome. It's a very human thing to do. We always think we are more able than we really are.
Do understand that she may have died in this manner even with months of rehab.
Again, I am so very sorry for your loss.
Rehab is not a prison. If your mother was of sound mind, she had the ability to sign herself out of rehab the same way she could've signed herself out of the hospital as well.
Wishing you peace and acceptance with the outcome of this unfortunate situation.