University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Hirschfeld v. Stone PC-NY-0011
Docket / Court 99-11693 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Prison Conditions
Attorney Organization Legal Services/Legal Aid
Case Summary
On December 1, 1999, the plaintiffs, confined to Mid-Hudson Forensic Psychiatric Center (Mid-Hudson) in New York, brought a civil rights action under 42 U.S.C. § 1983 in the Southern District of New York against hospital officials, physicians and the New York mental health commissioner. The ... read more >
On December 1, 1999, the plaintiffs, confined to Mid-Hudson Forensic Psychiatric Center (Mid-Hudson) in New York, brought a civil rights action under 42 U.S.C. § 1983 in the Southern District of New York against hospital officials, physicians and the New York mental health commissioner. The plaintiffs, represented by Mental Hygiene Legal Service and the Special Litigation Unit of Legal Aid Society, were criminal defendants who had been found incapacitated to stand trial. In their suit, the plaintiffs alleged violations of constitutional privacy rights via disclosure of confidential psychiatric and medical information. The plaintiffs argued that the use of "Fitness Reports" by the defendant, Mid-Hudson, effectively disclosed to the public confidential information because the reports were placed in unsealed court files accessible to the general public. "Fitness Reports" typically included the following: current mental status exam, observations regarding fitness, history of dangerousness, history relevant to fitness, current treatment, DSM IV diagnosis and forensic psychiatric opinion.

On May 9, 2000, the United States District Court for the Southern District of New York (Judge William H. Pauley III) granted class certification to all incapacitated criminal defendants confined at Mid-Hudson. Hirschfeld v. Stone, 193 F.R.D. 175 (S.D.N.Y. 2000). The court also granted the preliminary injunction requested by the plaintiffs and ordered that "Fitness Reports" could no longer be used in proceedings to determine a criminal defendant's capacity to proceed to trial. The court found that irreparable harm was caused by the disclosure of the personal information in question, and the state's interest in including personal information in reports submitted to courts and used to determine capacity was outweighed by the defendants' privacy interests.

On August 16, 2001, Judge Pauley issued a consent order stating that the plaintiffs' claims for injunctive relief would remain on the Court's active calendar for one year and then be moved to the Court's inactive calendar for an additional two year period. The case was closed on February 11, 2002.

Tom Madison - 01/23/2006
Priyah Kaul - 11/18/2014


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Due Process
Content of Injunction
Preliminary relief granted
Preliminary relief granted
Defendant-type
Jurisdiction-wide
Jurisdiction-wide
Disability
Mental impairment
Mental impairment
General
Classification / placement
Classification / placement
Confidentiality
Confidentiality
Medical/Mental Health
Mental health care, general
Mental health care, general
Plaintiff Type
Private Plaintiff
Private Plaintiff
Type of Facility
Government-run
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) New York State Department of Corrections
Plaintiff Description All incapacitated criminal defendants confined at Mid-Hudson
Indexed Lawyer Organizations Legal Services/Legal Aid
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Preliminary injunction / Temp. restraining order
Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 2001 - 2003
Case Closing Year 2003
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
99-11693 (S.D.N.Y.) 04/04/2002
PC-NY-0011-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Memorandum and Order 05/09/2000 (193 F.R.D. 175) (S.D.N.Y.)
PC-NY-0011-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Pauley, William H. III (S.D.N.Y.)
PC-NY-0011-0001 | PC-NY-0011-9000
Monitors/Masters None on record
Plaintiff's Lawyers Feld, Dennis B. (New York)
PC-NY-0011-0001 | PC-NY-0011-9000
Johnson, Laura R. (New York)
PC-NY-0011-0001 | PC-NY-0011-9000
Licul, Valdi (New York)
PC-NY-0011-0001 | PC-NY-0011-9000
Defendant's Lawyers Jaffe, William B. (District of Columbia)
PC-NY-0011-0001 | PC-NY-0011-9000
Other Lawyers None on record

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