On November 25, 1974, patients at the Rio Piedras Psychiatric Hospital (RPPH) in San Juan, Puerto Rico, filed a class action lawsuit under 42 U.S.C. §1983 against the Commonwealth of Puerto Rico in the U.S. District Court for the District of Puerto Rico. The plaintiffs, represented by Puerto Rico Legal Services and the Civil Action and Education Corporation, asked the court for declaratory and injunctive relief, alleging that their constitutional rights had been violated by overcrowding, inadequacies in the physical facilities, lack of security for personal belongings, lack of pillows, poor laundry service, unpleasant odors, insufficient therapeutic treatment, insufficient staffing, inadequate classification standards, and discrimination on the basis of geographical origin. The plaintiffs also alleged that the defendants would place them naked in isolation rooms, which lacked toilet facilities. Amicus Curae in the case included the National Alliance for the Mentally Ill, the Comite De Convergencia Por La Salud Mental En Puerto Rico, and the Colegio De Medicos Cirujanos De Puerto Rico.
On June 3, 1977, the court issued a consent decree and closed the case. The decree detailed 86 standards that the parties stipulated would be observed at RPPH in the future, and it included short term plans to remove patients with intellectual disabilities, as well as other long term patients who didn't require hospitalization to the Cayey and Bayamon Psychosocial and Rehabilitation Centers. It also included the placement of additional patients in a foster care home program. The decree contained no express provisions that any of the 86 standards would be effectuated at any other facility than RPPH.
There was little activity in the case for seven years. On February 8, 1985, the district court (Judge Hector Manuel Laffitte) appointed Dr. David Helfeld as Special Master in the case, charging him to report back to the court on the progress of the defendants. On August 10, 1987, in response to the Special Master's report detailing the overcrowding at RPPH, the district court (Judge Laffitte) ordered that 144 patients be transferred to the Guerrero facility, noting that the patients should receive care and treatment consistent with the 86 stipulations in the original consent decree.
On June 28, 1988, the defendants asked the district court to reclose the case, arguing that they had substantially complied with the court's orders. On December 8, 1988, the district court (Judge Laffitte) denied this motion, ruling that the defendants were not in full compliance with the decree.
On June 12, 1989, the plaintiffs asked the district court to hold the defendants in contempt, alleging that the patients that had been transferred to the Guerrero facility were not receiving adequate treatment. The defendants objected to this, arguing that the district court didn't have jurisdiction over Guerrero because the consent decree only pertained to RPPH. On December 28, 1989, the district court (Judge Laffitte) ruled that the consent decree did apply to RPPH patients being treated at the Guerrero facility.
On January 16, 1990, the defendants asked the district court for sanctions, stating that the plaintiff class had never been properly certified by the court. On March 6, 1990, the district court (Judge Laffitte) dismissed the defendants' request, holding that the action had been maintained as a class action since class certification was satisfied when the court approved the original stipulated agreement. The court also found that the notice requirement had been satisfied because no class member had complained during the entire 14 years of the litigation. The court stated that the defendants' arguments were frivolous and assessed sanctions of $1,500.00 in attorneys' fees against the counsel for the defendants. The defendants appealed this order. On December 18, 1991, the U.S. Court of Appeals for the First Circuit (Judge Levin H. Campbell) affirmed the district court's ruling that the lawsuit could proceed as a class action, but reversed and remanded the district court's ruling that the consent decree would apply to the Guerrero facility. Navarro-Ayala v. Hernandez-Colon, 951 F.2d 1325 (1st Cir. 1991).
On remand, the district court (Judge Laffitte) ordered the parties to submit briefs on an appropriate remedial action for the defendants' systematic denial of rights under the Mental Health Code. The court also ordered the Special Master to investigate whether the medical directors at Guerrero was presently implementing the provisions of the Mental Health Code. The defendants appealed both orders. On February 7, 1992, the First Circuit (Judge Campbell) dismissed the appeal, holding that the appellate court had no jurisdiction in the matter since the district court's orders were not final orders. Navarro-Ayala v. Hernandez-Colon, 956 F.2d 348 (1st Cir. 1992).
The plaintiffs asked the district court to impose sanctions on the Assistant Secretary of Mental Health for violating Rule 11 of the Federal Rules of Civil Procedure by falsely certifying to the court that patients at the institution could leave the hospital "at any time they want." On July 8, 1991, the district court (Judge Laffitte) granted the plaintiffs' request and issued monetary sanctions in the amount of $20,000.00. Navarro-Ayala v. Hernandez-Colon, 143 F.R.D. 460 (D.P.R. 1991). The defendants appealed. On July 13, 1992, the First Circuit Court of Appeals (Judge Bruce Marshall Selya) affirmed the district court's decision to impose sanctions, but reduced the amount from $20,000.00 to $6,500.00. Navarro-Ayala v. Nunez, 968 F.2d 1421 (1st Cir. 1992).
In February 1992, the defendants filed a motion (signed by attorney Kenneth Colon) asking the district court to reconsider its reappointment of the Special Master. After considering and rejecting the motion, the district court (Judge Laffitte) decided that Colon had violated Rule 11 of the Federal Rules of Civil Procedure and sanctioned him $500.00. Colon appealed. On August 20, 1993, the First Circuit (Judge Breyer) reversed the district court's award of sanctions, holding that they were unwarranted. Navarro-Ayala v. Hernandez-Colon, 3 F.3d 464 (1st Cir. 1993).
As recounted in the District Court Order from January 10, 2005 (Judge H. Laffitte), the parties, on August 11, 2000, filed a Joint Stipulation and Order of Dismissal, asserting substantial compliance with the Consent Decree, pledging to maintain the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) accreditation, and agreeing to maintain a yearly appropriated budge of at least $18,929,000.00 and to adequately provide for the health, welfare, safety and treatment of the patients at RPPH. The Court adopted the joint stipulation and order, and thereafter, on January 28, 2002, the court dismissed the case, providing that the Joint Stipulation and Order entered into court, on August 11, 2000, remain in full force to protect the patients of the RPPH.
On January 10, 2005, the Court (Judge H. Laffitte) entertained a motion asserting that RPPH was not in substantial compliance with the consent decree and January 2002 order. Specifically, the plaintiffs claimed that the RPPH budget was reduced beneath the court-ordered amount and that the pre- and post-hospitalization services were inadequate. The Court determined that RPPH had in fact increased its budget and improved its pre- and post-hospitalization services. Nonetheless, the Court increased the budgetary mandate of $18,929,000.00 to $23,000,000.00 per fiscal year. It also reasserted its prior dismissal of the case, concluding that there was no evidence of further constitutional violations that warrant further judicial involvement in the case.
On September 26, 2014, a group of mental health patients at RPPH moved to reopen the case, claiming that RPPH had failed to maintain adequate staffing and funding levels, and that the patients feared that important services would be eliminated. As of November 24, 2014, the Court had not yet ruled on the motion to reopen the case. The case remains closed. Kristen Sagar - 07/19/2006
Nick Kabat - 11/27/2014