On August 25, 2011, an individual with intellectual disabilities filed this lawsuit in the U.S. District Court for the Northern District of Florida. The plaintiff, represented by a non-profit impact litigation firm, sued the director for the Agency for Persons with Disabilities (APD) pursuant to 42 U.S.C. §§ 1983 and 1988, claiming violations of the Due Process Clause of the Fourteenth Amendment. The plaintiff was involuntarily committed to residential services pursuant to a Florida statute but never received a periodic review of his continued need for involuntary confinement. Thus, the plaintiff asked the court for a permanent injunction that would require the defendant to adopt policies and procedures to ensure that clients who are committed to the defendant's care and custody receive state-initiated, periodic review of their involuntary commitment.

On December 19, 2011, District Judge William Stafford denied the defendant's motion to dismiss for failure to state a claim on the basis that the plaintiff had provided sufficient allegations to survive the motion.

After the parties engaged in discovery, on May 22, 2012, Judge Stafford granted the defendant's motion for summary judgment on the basis that the APD successfully set up a nonadversarial scheme that allowed behavioral specialists the flexibility to perform the tasks and make decisions for which they were trained, without having to spend unnecessary time in periodic court proceedings. The court reasoned that this scheme, when applied specifically to the plaintiff's case, was sufficient under the due process clause and periodic, judicial review of involuntary commitment was not required. 2012 WL 1886438 (N.D. Fla. May 22, 2012).

On August 10, 2012, the plaintiff filed an appeal to the US Court of Appeals for the Eleventh Circuit. The Eleventh Circuit held on August 20, 2013 that the Supreme Court of Florida had to answer three certified questions related to the case because the Supreme Court of Florida is the “arbiter[] of Florida law.” These questions asked whether the “support plan” under a Florida statue requires that APD “consider[s] the propriety of a continued involuntary admission for residential services,” if APD is required under law “to petition the circuit court for the release” of a person from involuntary admission if the circumstances surrounding the admission have changed, and if Florida law requires that involuntary admissions are periodically reviewed. 736 F.3d 959, 973 (11th Cir. 2013).

On May 14, 2015, the Florida Supreme Court held that APD was not required to “consider the propriety of continued involuntary admission” and APD did not have “to petition the circuit court for the release” of a person who was involuntarily admitted but the circumstances surrounding the admission had changed. 175 So. 3d 710 (Fla. 2015). The case then returned to the Eleventh Circuit.

On October 15, 2015, the Eleventh Circuit delivered an opinion reversing the Florida Supreme Court’s decision and remanding the case to the district court on the basis that the APD scheme was not constitutionally adequate. The court held that Florida’s system was in violation of the Due Process Clause because it did not require continued involuntary commitment to be reviewed by a decision-maker with the authority to order release.

The case was dismissed with prejudice on July 26, 2016. The parties filed a joint stipulation of dismissal, presumably due to a private settlement.

The case is now closed.

Maria Ricaurte - 10/25/2015
Amelia Huckins - 02/02/2017


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