Background On May 5, 1998, inmates in the Suffolk County Jail in New York filed a putative class action complaint on behalf of all individuals with mental illnesses facing civil commitment in jails and state-run hospitals. The suit also contained some individual claims from an individual plaintiff who was confined in Suffolk County jail and claims from the Mental Disability Law Clinic of Touro Center. The named defendants were various state officials in New York, the New York State Office of Mental Health, individual doctors who worked for Office of Mental Health facilities, and officials from a private psychiatric hospital in New York in the U.S. District Court for the Eastern District of New York.
It is important to note that because of the lack of access to early documents in this case, the claims of the different plaintiffs below may not be complete and may not include some claims listed in early amendments of the complaint.
Class ClaimsThe class of individuals facing civil commitment in hospitals in New York brought a number of claims under 42 U.S.C. §1983, alleging violations of the Fourth and Fourteenth Amendments of the United States Constitution. They alleged that the defendants had violated the Americans with Disabilities Act and New York Criminal Procedure laws. These claims included treating mentally ill individuals who were facing civil commitment because they were found incompetent to stand trial unequally to other patients facing civil commitment. The class also claimed non-dangerous individuals were being committed, that Office of Mental Health professionals were not being properly trained on involuntary commitment procedures, and that the internal guidelines for civil commitment decisions were unclear. The Class claimed these problems existed much more broadly than state run hospitals. They alleged all other facilities with the authority to civilly commit individuals in New York under the NY Mental Hygiene Law were committing such violations. The Class thus also brought suits against private facilities in the state. The Class plaintiffs requested attorney fees, monetary damages, costs, and injunctive relief. The Class plaintiffs requested class certification the same day.
Individual Plaintiff’s ClaimsThe individual plaintiff involved in this case was a man living in New York who had been found incompetent to stand trial and involuntarily committed in an Office of Mental Health Facility. The Individual Plaintiff asserted violations of his Eighth and Fourteenth Amendment rights under the United States Constitution and violations of state common law. He filed the constitutional claims under 42 U.S.C. §1983. The Individual Plaintiff’s claims involved the length of time he was involuntarily confined, the fact that he was confined despite being non-dangerous, and inadequate psychiatric treatment leading up to his confinement, while he was still in custody in the jail. The individual plaintiff requested attorney fees, monetary damages, costs, and injunctive relief.
Class certificationOn March 12, 1999, the U.S. District Court for the Eastern District of New York, (Judge Charles Proctor Sifton) certified the plaintiff class and certified a separate defendant class of local criminal court judges. Judge Sifton defined the plaintiff class as, “all individuals who have been or will be: (1) charged with a minor felony or misdemeanor, (2) evaluated to determine whether they are competent to stand trial, (3) found by court appointed psychiatrists to lack the capacity to stand trial, and (4) confined to a local jail pending a determination of competency while awaiting a determination of the competency issue by the local criminal court.” The defendant class was defined as containing “local criminal court judges.” The court declined to certify a defendant class of local sheriffs.
2002 Order and OpinionThe court addressed a number of motions on December 20, 2002. First, the plaintiffs sought to modify their class certification granted in 1999, expanding the class to include more individuals. Judge Sifton allowed the plaintiffs to certify a “Civil Commitment subclass” defined as “all individuals in the counties of Kings, Queens, Richmond, Nassau, and Suffolk who are subject to civil commitment evaluations.” The court clarified that only the Law Clinic can represent this subclass. They were also allowed to certify and jointly represent the Incompetency Subclasses.
Second, the City Defendants moved to dismiss on jurisdictional and standing grounds. The court denied their motion to dismiss for the claims brought by the individual plaintiff, but not for the classes represented by the Law Clinic.
Third, the individual defendants who worked as doctors moved for summary judgment. They argued the constitutional claims against the individual doctors should fail because the doctors were not “state actors,” and that the state court claims for lack of subject matter jurisdiction. The court granted this motion.
Finally, the plaintiffs sought to be granted access to emergency rooms operated by the defendants. The court granted this.
2004 Motion and OrderIn 2004, one of the defendants representing one of the private hospitals named in the suit moved to dismiss several of the claims against them. He challenged the claims of relief on the basis of the law the plaintiffs sought to apply, standing issues, and other grounds. The judge granted the defendant’s motion to dismiss the claim that the hospital lacked guidelines instructing physicians when to properly order confinement.
2008 Motion for Summary JudgmentIn 2008, The New York City Department of Corrections asked the court to grant them summary judgment on four of the causes of action involving “confinement of non-dangerous individuals” and their procedures for deciding whether an individual needed to be confined. The same year, Justice Cahill asked for summary judgment on the issues of the length of time individuals were being confined while the court decided on their capacity to stand trial. On August 26, 2008 the court granted these motions and those claims against NYC’s Department of Corrections and Justice Cahill were dismissed. However, Judge Sifton clarified the Department of Corrections and Cahill were not eliminated as parties from the action because other claims against them still existed.
SettlementsThe plaintiffs began settlement negotiations with various defendants starting in 2000. On April 25, 2005 the plaintiffs reached a settlement with the New York City Department of Corrections and the Sheriff’s office of Suffolk County. The defendants in this settlement agreed to create more record keeping practices and to implement a new policy that all class members would be transported to an appropriate facility within three days after their evaluation by doctors. The plaintiff’s counsel monitored the defendant’s progress. The defendants were required to provide documents to plaintiff’s counsel in four months after the start of the settlement to show their progress. The settlement also provided for reasonable attorney’s fees, which would be determined at a later date.
On April 14, 2007 the plaintiff also reached a settlement agreement with the New York City Health and Hospital Corporation. The HHC agreed to create new, standardized Risk Assessment Forms for the patients they see, provide training to their employees, pay reasonable attorney’s fees, and provide the plaintiff counsel with records so the plaintiff counsel can monitor HHC’s decision-making in cases of involuntary commitment. The Eastern District of New York Court would retain jurisdiction over this settlement. The defendants agreed to complete all the terms of the settlement within 150 days.
The plaintiffs reached a settlement with the Office of Mental Health (OMH) on December 9, 2009. Like the other settlements, this settlement consisted to changes OMH would make to their commitment procedures to comply with the Fourteenth Amendment and state criminal procedure laws. This process would be monitored by the plaintiff counsel and monitoring would last for three years. In addition, OMH agreed to pay plaintiff’s counsel $10,000 for attorney’s fees.
In total, plaintiffs ended up receiving $104,000 in attorney’s fees.
2012 WithdrawalOn April 24, 2012, the plaintiff voluntarily withdrew one of their Fourteenth Amendment claims against the state, individual, and private hospital defendants regarding their civil commitment procedure. The reason why the plaintiff withdrew this claim is unknown
Sixth Amended ComplaintThe plaintiffs filed their sixth (and final) amended complaint on August 29, 2014. This complaint asserted additional claims against the private hospital defendants for violating the Americans with Disabilities Act during treatment of class members. The plaintiffs wanted to amend their complaint to include additional state law claims, but the court rejected their request to do so under the Eleventh Amendment.
2016 Motion to DismissOn March 31, 2016 the Eastern District of New York addressed a motion from one of the individual doctor defendants for summary judgement on the individual plaintiff’s Fourteenth Amendment claim against him. The court granted this motion for summary judgment and the claims against this defendant were dismissed.
2016 Decertification of SubclassIn the same 2016 opinion, Judge Garaufis also re-visited the class certifications granted earlier, given the changes in the case. The remaining state defendants asked for both the Civil Commitment and the Incompetency subclasses to be decertified. Both subclasses were decertified as the Judge stated neither had a class representative.
Case’s EndingIn September of 2016, the court asked the parties to file status reports and the case was dismissed on the 27th of September after both parties agreed there were no remaining issues in the case. The plaintiffs filed a motion for appeal, but withdrew it for unknown reasons. The case is now closed.
Kristen Sagar - 10/13/2006
Sarah Reasoner - 04/18/2019
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