Accardi v. County of Suffolk

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 14, 2025
Docket24-903
StatusUnpublished

This text of Accardi v. County of Suffolk (Accardi v. County of Suffolk) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Accardi v. County of Suffolk, (2d Cir. 2025).

Opinion

24-903 Accardi v. County of Suffolk

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 14th day of January, two thousand twenty-five.

Present: GUIDO CALABRESI, MICHAEL H. PARK, ALISON J. NATHAN, Circuit Judges. __________________________________________

JAMES K. ACCARDI,

Plaintiff-Appellant,

v. 24-903

COUNTY OF SUFFOLK, SUFFOLK COUNTY POLICE DEPARTMENT, LIEUTENANT ANDREW MANFREDONIA, AND LIEUTENANT SEAN BERAN,

Defendants-Appellees.* __________________________________________

FOR PLAINTIFF-APPELLANT: RAYMOND NEGRON, Law Office of Raymond Negron, Mount Sinai, NY.

FOR DEFENDANTS-APPELLEES: ANNE CATHERINE LEAHEY, Suffolk County Department of Law, Hauppauge, NY.

* The Clerk of Court is respectfully directed to amend the caption accordingly. Appeal from a judgment of the United States District Court for the Eastern District of New

York (Gonzalez, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Plaintiff-Appellant James Accardi was hospitalized involuntarily for five days in a

psychiatric facility after a series of domestic incidents. He sued Defendants Suffolk County,

Suffolk County Police Department, Lieutenant Andrew Manfredonia, Lieutenant Sean Beran, and

various police officers for violations of his Fourth and Fourteenth Amendment rights, among other

claims. Defendants filed a motion for summary judgment, which the district court granted and

then entered judgment for Defendants and dismissed the case.

On appeal, Accardi argues the district court erred in dismissing the first count of his four-

count complaint because there existed a genuine dispute of material fact about whether Defendant

Manfredonia lied to healthcare providers in a way that induced them to keep Accardi hospitalized

for treatment. We assume the parties’ familiarity with the underlying facts, the procedural history

of the case, and the issues on appeal.

“We review a district court’s decision to grant summary judgment de novo, construing the

evidence in the light most favorable to the party against which summary judgment was granted

and drawing all reasonable inferences in its favor.” Halo v. Yale Health Plan, Dir. of Benefits &

Recs. Yale Univ., 819 F.3d 42, 47 (2d Cir. 2016) (internal quotation marks omitted). Summary

judgment is appropriate “if the movant shows that there is no genuine dispute as to any material

fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).

2 I. Legal Framework

A. New York Mental Hygiene Law

Under New York law, police officers “may take into custody any person who appears to

be mentally ill and is conducting himself or herself in a manner which is likely to result in serious

harm to the person or others.” N.Y. Mental Hygiene Law § 9.41(a). Officers may also “direct

the removal of such person or remove him or her to . . . any comprehensive psychiatric emergency

program specified in subdivision (a) of section 9.40 of this article.” Id. Similarly, officers may

take an individual “who appears to be incapacitated by alcohol and/or substances to the degree that

there is a likelihood to result in harm to the person or to others . . . to a treatment facility for

purposes of receiving emergency services.” Id. § 22.09(b)(2). New York law defines

“likelihood to result in serious harm” as:

(i) a substantial risk of physical harm to the person as manifested by threats of or attempts at suicide or serious bodily harm or other conduct demonstrating that the person is dangerous to himself or herself, or (ii) a substantial risk of physical harm to other persons as manifested by homicidal or other violent behavior by which others are placed in reasonable fear of serious physical harm.

Id. § 22.09(a)(3).

B. Fourteenth Amendment

“An involuntary civil commitment is a massive curtailment of liberty, and it therefore

cannot permissibly be accomplished without due process of law.” Rodriguez v. City of New York,

72 F.3d 1051, 1061 (2d Cir. 1995) (cleaned up). More specifically, “[s]ubstantive due process

prohibits states from involuntarily committing nondangerous mentally ill individuals.” Bolmer

v. Oliveira, 594 F.3d 134, 142 (2d Cir. 2010). “[T]he New York State civil commitment scheme,

considered as a whole and as interpreted . . . to include a showing of dangerousness, meets

3 minimum due process standards.” Project Release v. Prevost, 722 F.2d 960, 973–74 (1983); see

also Rodriguez, 72 F.3d at 1062 (“New York’s overall statutory scheme governing involuntary

commitments has been held facially sufficient to meet the requirements of due process.”).

C. Fourth Amendment

“[T]he Fourth Amendment applies to involuntary commitment.” Glass v. Mayas, 984

F.2d 55, 58 (2d Cir. 1993). It “requires that an involuntary hospitalization may be made only

upon probable cause, that is, only if there are reasonable grounds for believing that the person

seized is subject to seizure under the governing legal standard.” Id. (internal quotation marks

omitted). Probable cause is a “complete defense to a constitutional claim of false arrest.” Betts

v. Shearman, 751 F.3d 78, 82 (2d Cir. 2014) (internal citation omitted).

New York Mental Hygiene Law § 9.41 is “consistent[] with the requirements of the Fourth

Amendment and [we] therefore assume that the same objective reasonableness standard is applied

to police discretion under this section.” Kerman v. City of New York, 261 F.3d 229, 240 n.8 (2d

Cir. 2001). Thus, a “warrantless seizure for the purpose of involuntary hospitalization may be

made only upon probable cause, that is, only if there are reasonable grounds for believing that the

person seized is dangerous to [him]self or to others.” Singh v. City of New York, 23-24-cv, 2024

WL 319117, at *3 (2d Cir. Jan. 29, 2024) (internal quotation marks omitted).

D. Misrepresentations in a Probable Cause Determination

An allegation that a deliberate misrepresentation influenced a probable cause determination

gives rise to a mixed question of law and fact. To defeat a defendant’s motion for summary

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Related

Bolmer v. Oliveira
594 F.3d 134 (Second Circuit, 2010)
Project Release v. Prevost
722 F.2d 960 (First Circuit, 1983)
Glass v. Mayas
984 F.2d 55 (Second Circuit, 1993)
Rodriguez v. City of New York
72 F.3d 1051 (Second Circuit, 1995)
John Betts v. Martha Anne Shearman
751 F.3d 78 (Second Circuit, 2014)
Kerman v. City of New York
261 F.3d 229 (Second Circuit, 2001)

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Accardi v. County of Suffolk, Counsel Stack Legal Research, https://law.counselstack.com/opinion/accardi-v-county-of-suffolk-ca2-2025.