Mental Health Ass'n v. Corbett
2012 Pa. Commw. LEXIS 294
| Pa. Commw. Ct. | 2012Background
- Petitioners are nonprofit MH/ID advocacy groups challenging DPW funding and a proposed shift of MH/ID monies to the HSDF Block Grant.
- DPW administers MH/ID funds through OMHSAS and ODP, with HSDF funding covering other community services.
- MH/ID Act sections require DPW to provide and assist in mental health services and to make related grants and reimbursements.
- Governor proposed in 2012 budget to cut DPW funding for MH/ID and transfer MH/ID funds to HSDF, prompting MH/ID Act changes.
- Petition filed March 14, 2012 seeking mandamus, declaratory judgment, and injunction; AG objected to the claims as non-justiciable.
- Court held that petition presents non-justiciable political questions and violates separation of powers, sustaining objections and dismissing petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether petition seeks relief for adequate MH/ID funding (Count I). | Petitioners contend DPW failure to ensure adequate MH/ID funding violates the MH/ID Act. | Corbett argues this is a political question outside judicial review. | Non-justiciable political question; objections sustained. |
| Whether petition seeks to prevent transfer of MH/ID funds to HSDF (Count II). | Petitioners argue against shifting MH/ID funds into HSDF Block Grant. | Corbett maintains this is a political question beyond judicial review. | Non-justiciable political question; objections sustained. |
Key Cases Cited
- Sweeney v. Tucker, 473 Pa. 493 (Pa. 1977) (political-question doctrine and separation of powers applied)
- Baker v. Carr, 369 U.S. 186 (U.S. 1962) (standard for determining nonjusticiable political questions)
- Commonwealth v. TAP Pharm. Prods., Inc., 36 A.3d 1112 (Pa.Cmwlth.2011) (factors for political-question analysis)
- Marrero ex rel. Tabalas v. Commonwealth, 559 Pa. 14 (Pa. 1999) (legislature funding decisions often non-justiciable)
- Finn v. Rendell, 990 A.2d 100 (Pa.Cmwlth.2010) (court cannot order budgetary appropriations)
- City & Cnty. of Phila. ex rel. Dep’t of Human Servs. v. Dep’t of Public Welfare, 941 A.2d 766 (Pa.Cmwlth.2008) (budget allocations not subject to judicial hearing)
- Jubelirer v. Rendell, 953 A.2d 514 (Pa. 2008) (balance between executive proposals and legislative appropriations)