University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Sciarrillo ex rel. St. Amand v. Christie ID-NJ-0005
Docket / Court 2:13-cv-03478-SRC-CLW ( D.N.J. )
State/Territory New Jersey
Case Type(s) Intellectual Disability (Facility)
Public Benefits / Government Services
Special Collection Olmstead Cases
Case Summary
On June 5, 2013, 35 adult disabled individuals filed a lawsuit in the U.S. District Court for the District of New Jersey under the Americans with Disabilities Act ("ADA"), the Rehabilitation Act ("RA"), and the Social Security Act (Medicaid) - as well as a § 1983 constitutional due process claim ... read more >
On June 5, 2013, 35 adult disabled individuals filed a lawsuit in the U.S. District Court for the District of New Jersey under the Americans with Disabilities Act ("ADA"), the Rehabilitation Act ("RA"), and the Social Security Act (Medicaid) - as well as a § 1983 constitutional due process claim against the State of New Jersey. The plaintiffs, represented through their legal guardians by private counsel, asked the court for declaratory and injunctive relief to prevent the closing of two residential care facilities where the plaintiffs resided. The claims argued that the planned closures would violate the plaintiffs' rights or result in situations where violation of those rights would occur.

Specifically, in regard to the ADA claims, the plaintiffs claimed that discharges or transfers from their current residences were being forced without their consent and without appropriate recommendation from treating professionals. This, they argued, violated the plaintiffs' rights under the ADA and entitled them to the relief sought. The plaintiffs claimed that their discharge or transfer from their current residence would violate the RA's integration requirement. Further, that the State utilized criteria and methods of administration that subjected the plaintiffs to discrimination based on their disability. In regards to the Medicaid claim made through the Social Security Act, the plaintiffs claimed the State failed to ensure the plaintiffs needs and preferences were being met in their multidisciplinary plan. The plaintiffs claim that the discharge process, and its lack of safeguards to prevent harm to the plaintiffs, violated plaintiffs' rights not to be deprived of life or liberty without due process of law.

On September 9, 2013, defendants moved to dismiss the complaint under Rule 12(b)(6) for failure to state a claim. The United States of America additionally filed a statement of interest arguing that plaintiffs failed to state a cause under the ADA and RA. On December 13, 2013, the District Court (Judge Stanley R. Chesler) granted the defendant's motion to dismiss. The court found that each claim either did not meet the factual standard required in pleading or that, in the case of the Medicaid claim, the cited statues did not apply to private actions.

The plaintiffs filed a notice of appeal of the order on motion to dismiss on January 10, 2014.

Patrick Branson - 09/24/2014


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Defendant-type
Hospital/Health Department
Jurisdiction-wide
Disability
Integrated setting
Mental impairment
Discrimination-basis
Disability (inc. reasonable accommodations)
General
Placement in mental health facilities
Reassessment and care planning
Medical/Mental Health
ICF/MR & HCFA standards
Mental health care, general
Mental Disability
Intellectual/developmental disability, unspecified
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
42 U.S.C. § 1983
Defendant(s) New Jersey Department of Human Services
New Jersey Department of Human Services Division of Developmental Disabilities
New Jersey Department of Human Services Division of Developmental Disabilities
Plaintiff Description Plaintiffs are all adults who are severely mentally disabled and represented by a legal guardian. Each Plaintiff was a resident at either the Woodridge Development Center in Woodbridge, NJ or the North Jersey Developmental Center in Totowa, NJ.
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Docket(s)
2:13-cv-03478-SRC-CLW (D.N.J.) 01/10/2014
ID-NJ-0005-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint 06/05/2013
ID-NJ-0005-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Opinion 12/13/2013 (2013 WL 6586569) (D.N.J.)
ID-NJ-0005-0002.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Chesler, Stanley R. (D.N.J.) [Magistrate]
ID-NJ-0005-0002 | ID-NJ-0005-9000
Waldor, Cathy L (D.N.J.) [Magistrate]
ID-NJ-0005-9000
Monitors/Masters None on record
Plaintiff's Lawyers Archer, Thomas A. (Pennsylvania)
ID-NJ-0005-0001 | ID-NJ-0005-9000
York, Thomas B. (Pennsylvania)
ID-NJ-0005-0001
Defendant's Lawyers Hughes, Gerard Andrew (New Jersey)
ID-NJ-0005-9000
Other Lawyers None on record

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