In 1983, a number of patients confined to St. Elizabeths Hospital, a public mental health facility, filed a habeas corpus petition in D.C. Superior Court against the United States. The plaintiffs, represented by the Mental Health Law Project and the Public Defender's office, claimed that they had been committed to the hospital upon a showing of mental illness by a preponderance of the evidence--the standard in force at the time of their confinement--but that the Supreme Court had later held that the constitutionally required standard was by "clear and convincing evidence." The plaintiffs wanted this later-established standard retroactively applied to their confinement.

The United States removed the case to the United States District Court for the District of Columbia. The District Court (Judge Barrington D. Parker) certified a class consisting of all patients committed to the facility for more than six months. The plaintiffs moved for partial summary judgment with regard to a subclass of patients who had been committed before 1973, under the "preponderance of the evidence" standard. And on May 19, 1987, the District Court (Judge Parker) granted their motion, holding that the subclass's due process rights had been violated, and ordered judicial review of their present commitment status under the prevailing constitutional standards.

On Oct. 1, 1987, responsibility for St. Elizabeths shifted from the federal government to the District of Columbia. The federal district court then substituted the responsible District of Columbia official and transferred the subclass action back to the Superior Court of the District of Columbia, directing that each member of the subclass be provided with a commitment hearing. The district court retained jurisdiction over the subclass and required the superior court to file status reports. On March 20, 1992, the federal district court remanded all remaining issues to the Superior Court.

A great majority of the patients received favorable results from their commitment hearings. They then moved under the Equal Access to Justice Act to recover attorneys' fees from the federal government for attorneys' fees incurred during proceedings before the federal district court and before the Superior Court. The district court granted the requested attorneys' fees and the government appealed. On Feb. 15, 1994, the Circuit Court of Appeals for the District of Columbia affirmed the government's responsibility to pay fees associated with the action before the federal district court, but determined that it did not have to pay fees associated with the individual commitment hearings before the D.C. Superior Court. 15 F.3d 1126.

Andrew Junker - 11/06/2014


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