456 F.Supp.3d 126
D.D.C.2020Background
- Plaintiffs are three indefinitely and involuntarily civilly committed patients at Saint Elizabeths Hospital (a D.C. public psychiatric facility) who brought a putative class action challenging the Hospital’s COVID-19 response.
- Plaintiffs allege failures to follow CDC guidance: cohorting (grouping) COVID-positive/suspected patients instead of private isolation, returning symptomatic patients to general population after a single negative test, and inadequate social distancing, masking, testing, and quarantine of new admits.
- By late April 2020, dozens of staff and patients had tested positive and several patients and staff had died, raising an imminent risk to Plaintiffs.
- Plaintiffs moved for a temporary restraining order (TRO); the court conducted expedited meet-and-confer sessions with medical experts and held telephonic hearings.
- The court applied the Youngberg professional-judgment framework for civilly committed patients, found Plaintiffs likely to succeed on the merits as to two priority issues (isolation of exposed persons and returning symptomatic patients after one negative test), found irreparable harm and public interest favor injunctive relief, and granted the TRO in part (ordering compliance with CDC-type precautions) and deferred other relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hospital must isolate patients exposed to COVID-19 (not merely cohort) | Exposed patients should be medically isolated/closely monitored to prevent spread | Hospital says units are under quarantine and must balance psychiatric needs/patient autonomy | Court: Plaintiffs likely to succeed; current quarantine implementation falls short of CDC standards; TRO relief warranted to require closer isolation/monitoring as practicable |
| Whether symptomatic/suspected patients may be returned to general population after one negative test | Symptomatic patients should not be cleared on one negative test given false negatives; two negatives or clinical evaluation needed | Defendants read CDC guidance as permitting release after one negative test unless high clinical suspicion; Hospital says rapid onsite testing available | Court: Plaintiffs likely to succeed on this claim; Hospital’s practice of immediate return after one negative test departs from accepted standards absent clinical-suspicion review; TRO relief appropriate |
| Proper legal standard for civilly committed patients’ COVID-19 conditions | Plaintiffs invoke Youngberg and analogies to pretrial-detainee standards for excessive-risk conditions | Defendants say Youngberg’s professional-judgment standard governs; decisions presumptively valid if by professionals | Court: Applied Youngberg; recognized presumption for professional judgment but found record shows substantial departure on key practices here, so plaintiffs likely prevail on priority claims |
| Balance of equities / irreparable harm / public interest for TRO | Violation of constitutional rights and imminent health risk constitute irreparable harm; public health favors injunction | Defendants contend Hospital already implements most measures and needs discretion for clinical/psychiatric decisions | Court: Plaintiffs demonstrated irreparable harm; public interest and equities favor limited injunction that preserves clinicians’ on‑the‑spot judgment |
Key Cases Cited
- Youngberg v. Romeo, 457 U.S. 307 (establishes state duty and Youngberg "professional judgment" standard for involuntarily committed patients)
- Winter v. Natural Res. Def. Council, 555 U.S. 7 (standard for preliminary injunctive relief)
- Aamer v. Obama, 742 F.3d 1023 (discusses TRO/preliminary injunction factors in D.C. Circuit)
- LaShawn A. v. Dixon, 762 F. Supp. 959 (applying Youngberg balancing in institutional-care context)
- Mills v. District of Columbia, 571 F.3d 1304 (deprivation of constitutional rights and irreparable injury)
- Porter v. Illinois, 36 F.3d 684 (characterizing professional-judgment standard relative to negligence/recklessness)
- Pursuing America’s Greatness v. FEC, 831 F.3d 500 (government interest merges with public interest in injunction analysis)