25 F. Supp. 3d 233
E.D.N.Y.2014Background
- Plaintiff Patrick Bryant, a Suffolk County resident, was involuntarily transported and hospitalized in March 2011 after police contacted the OMH Mobile Crisis Unit about his complaints of threatening phone calls.
- OMH social worker Kristen Steele and two county police officers spoke with Bryant outside his home; he mentioned owning several nonfunctional collectible rifles. Steele reported him as manifesting mental illness and needing evaluation under N.Y. Mental Hygiene Law § 9.45.
- Dr. Brenda Garro (Stony Brook CPEP) evaluated Bryant for about three minutes and applied for involuntary admission under MHL § 9.37; Bryant was transferred to private Brunswick Hospital the next day.
- At Brunswick, admissions and certifications were made without psychiatrist-conducted evaluations (allegedly relying on earlier assessments); Bryant was held March 22–31, 2011 and billed for services he did not consent to.
- Plaintiff sued under 42 U.S.C. § 1983 (Fourth Amendment seizure and Fourteenth Amendment substantive and procedural due process claims), Title II ADA and Section 504 Rehabilitation Act claims, and state-law medical malpractice claims; defendants moved to dismiss in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment seizure by Steele | Steele lacked probable/arguable probable cause to authorize involuntary seizure | Actions were justified by information from police and reasonable grounds for evaluation | Claim against Steele survives; dismissal denied |
| Substantive due process against Dr. Garro | Garro deprived liberty by authorizing commitment without danger and without accepted risk-assessment | Fourth Amendment governs seizure claims; substantive due process inappropriate | Substantive due process claims dismissed in favor of Fourth Amendment framework |
| Procedural due process against Dr. Garro | Procedures used failed to satisfy MHL/due process accuracy standards | New York MHL satisfies due process; plaintiff pleads no specific statutory-procedural violation | Procedural due process claim dismissed for failure to allege specific procedural deficiency |
| ADA (Stony Brook) and Rehabilitation Act (Brunswick) | Hospitalization based on stereotyped assumptions about mental disability constitutes discrimination | Treatment decisions concerned factors proper to commitment inquiry; claims are effectively medical-malpractice recharacterizations | ADA and Rehab Act claims dismissed for failing to allege discrimination based on factors unrelated/improper to commitment decision (applying McGugan) |
| Supplemental jurisdiction over state malpractice claims against Brunswick | State malpractice claims arise from same facts as federal claims | Brunswick sought dismissal and remand of pendent state claims | Court exercises supplemental jurisdiction; malpractice claims against Brunswick remain |
| Eleventh Amendment immunity re: medical-bill relief against Stony Brook | Plaintiff seeks declaration/refund for billed services | Stony Brook is a state entity; sovereign immunity bars suit for monetary/declaratory relief | Claim relating to payment of medical bills dismissed for lack of subject-matter jurisdiction |
Key Cases Cited
- Arar v. Ashcroft, 532 F.3d 157 (2d Cir. 2008) (standard for subject-matter jurisdiction and burden on plaintiff)
- Sinochem Int’l Co. v. Malaysia Int’l Shipping Corp., 549 U.S. 422 (2007) (jurisdictional threshold principles)
- Makarova v. United States, 201 F.3d 110 (2d Cir. 2000) (plaintiff bears burden to show jurisdiction)
- LaFaro v. New York Cardiothoracic Group, PLLC, 570 F.3d 471 (2d Cir. 2009) (Rule 12(b)(6) pleading standards)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for complaints)
- McGugan v. Aldana‑Bernier, 752 F.3d 224 (2d Cir. 2014) (ADA/Rehab Act: discrimination requires consideration of factors unrelated/improper to treatment decision)
- United States v. University Hospital, 729 F.2d 144 (2d Cir. 1984) (Rehab Act prohibits discrimination where disability is unrelated to the services in question)
- Glass v. Mayas, 984 F.2d 55 (2d Cir. 1993) (involuntary hospitalization is a Fourth Amendment seizure)
- Rodriguez v. City of New York, 72 F.3d 1051 (2d Cir. 1995) (due process requires procedures that promise reasonable accuracy for involuntary commitment)