Brad H. v. City of New York
17 N.Y.3d 180
| NY | 2011Background
- Plaintiffs, mentally ill inmates, challenged NYC's discharge planning duties under the State Constitution and Mental Hygiene Law.
- A negotiated settlement was approved by Supreme Court on April 4, 2003, with implementation required by June 3, 2003.
- The agreement terminated five years after monitoring by Compliance Monitors began, with potential two-year extensions for ongoing noncompliance.
- Monitors were appointed May 6, 2003, began limited work in May, and issued a full-fledged first report in September 2003 after the implementation date.
- City argued the five-year term commenced May 6, 2003; plaintiffs argued it commenced June 3, 2003; court held monitoring began June 3, 2003 and term ended May 25/26, 2009.
- Plaintiffs moved May 22, 2009 for TRO/PI; Supreme Court denied dismissal, Appellate Division reversed, and the Court of Appeals ultimately addressed the termination date.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did monitoring begin for the termination clock? | Brad H. argues monitoring began on June 3, 2003, the implementation date. | City contends monitoring began May 19–28, 2003, before implementation. | Monitoring began June 3, 2003; termination date five years later. |
| Does termination depend on monitoring start or implementation date? | Term ends five years after monitoring begins, not on implementation date. | Term should track implementation date as the starting point. | Term begins five years after monitoring begins; interpretation adopted favors monitoring-begin date. |
| Is plaintiffs' May 2009 motion timely under the termination clause? | Motion filed before expiration since monitoring began before end of term. | Motion untimely if the five-year period ended earlier than May 2009. | Motion timely; five-year term ended May 25/26, 2009, after monitoring began on June 3, 2003. |
Key Cases Cited
- Vintage, LLC v Laws Constr. Corp., 13 N.Y.3d 847 (2009) (contracts interpreted by plain meaning when unambiguous)
- Samuel v Druckman & Sinel, LLP, 12 N.Y.3d 205 (2009) (contract interpretation and ambiguity principles)
- Greenfield v Philles Records, 98 N.Y.2d 562 (2002) (plain meaning and integration of contract terms)
- Consedine v Portville Cent. School Dist., 12 N.Y.3d 286 (2009) (ambiguity assessment within four corners of the document)
- Bailey v Fish & Neave, 8 N.Y.3d 523 (2007) (contract interpretation standards)
- Vermont Teddy Bear Co. v 538 Madison Realty Co., 1 N.Y.3d 470 (2004) (contextual interpretation of contract terms)
- Innophos, Inc. v Rhodia, S.A., 10 N.Y.3d 25 (2008) (extrinsic evidence admissible only if ambiguity exists)
- Brad H. et al. v City of New York, 17 N.Y.3d 180 (2011) (Court of Appeals confirms monitoring-begin date governs term; denies ambiguity)