English v. District of Columbia
405 U.S. App. D.C. 174
| D.C. Cir. | 2013Background
- English, involuntarily committed at St. Elizabeths since 1982, earned wages deposited in a DMH patient account.
- DMH billed English about $2,150 for care from July 2008–Jan 2009 and “Administrative Consent” signed July 14, 2009 acknowledged liability for charges.
- DMH notified of charges and reserved right to transfer funds; DMH removed $2,150 from English’s account in August 2009.
- English pursued a September 2009 DMH grievance, which progressed to an external reviewer who found merit and recommended judicial review.
- Director of DMH did not issue a final decision within regulatory deadlines; the grievance proceeded without a timely contested-case decision.
- September 2010, English filed suit in district court under 42 U.S.C. § 1983 and DCAPA, later coordinated with a federal dismissal; DC Court of Appeals dismissed for lack of contested case; district court’s dismissal affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there a due process violation from the funds withdrawal without proper notice? | English alleges lack of notice before removal. | DMH complied with notice via consent and invoice. | No due process violation; notice was adequate. |
| Did the DCAPA review procedure provide adequate process to satisfy due process? | DCAPA procedures were not adequately accessible or invoked. | DCAPA provides a post-deprivation remedy; procedures were available. | DCAPA procedures were available; failure to pursue them was not a due process defect. |
| Was DC Court of Appeals review proper without a contested-case proceeding? | Contested-case prerequisite to DC Court of Appeals review was not met. | Contested-case proceeding was necessary before review. | Dismissal proper; no jurisdiction without contested-case proceeding. |
| Did the district court err in declining supplemental jurisdiction over local claims? | Federal claims should not preclude state-law claims. | District court acted within discretion to dismiss supplemental claims. | No abuse of discretion; dismissal affirmed. |
Key Cases Cited
- Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (due process notice sufficiency standard)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (factors for procedural due process)
- Logan v. Zimmerman Brush Co., 455 U.S. 422 (U.S. 1982) (due process when state requires reasonable procedural rule)
- Capitol Hill Restoration Soc’y, Inc. v. Moore, 410 A.2d 184 (D.C. 1979) (contested-case prerequisite to review in DC courts)
- Krentz v. Robertson Fire Prot. Dist., 228 F.3d 897 (8th Cir. 2000) (availability of contested-case provisions from statutes/regulations)