Blanche C v. State of Maine Department of Health and Human Services

CourtSuperior Court of Maine
DecidedJuly 13, 2006
DocketKENap-05-44
StatusUnpublished

This text of Blanche C v. State of Maine Department of Health and Human Services (Blanche C v. State of Maine Department of Health and Human Services) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blanche C v. State of Maine Department of Health and Human Services, (Me. Super. Ct. 2006).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC, ss. DOCKET NO. AP-05-44

BLANCHE C.,

Petitioner

DECISION A N D ORDER

STATE OF MAINE, DEPARTMENT OF HEALTH AND HUMAN SERVICES,

Respondent

This matter is before the court on petition for review of final agency action by

petitioner Blanche C. ("petitioner") pursuant to M.R. Civ. P. 80C.

Blanche C. is a 50-year-old woman who was a patient at the Acadia Hospital

("Acadia"), a psychatric facility, for approximately two weeks in November 2002. She

had been admitted for severe depression, stemming from her impending divorce. She

was also quite angry and agtated, such that the hospital felt the need to place her under

emergency orders, which involved administering anti-psychotic medication and using

physical restraints. While restrained, petitioner injured her wrist. Within a month of

being released from the hospital, petitioner filed a grievance pursuant to the Rights of

Recipients of Mental Health Services ("RRMHS"). The grievance procedures involve

three levels, and petitioner first filed a Level I complaint, allegng that she was

involuntarily medicated, involuntarily restrained, and her subsequent wrist injury was

attended to inadequately. The Level I grievance was heard by the supervisor of her

unit, who denied it, as did the CEO of Acadia, at Level I1 of the grievance process. The

Level I11 grievance was then heard by the Division of Administrative Hearing at DHHS', which did find that some of petitioner's rights were violated, and

recommended, among other things, that DHHS issue an apology to the petitioner. In

h s final decision on the grievance, the DHHS Commissioner accepted the finding that

the petitioner was not examined w i h n 30 minutes of being place in restraints, per

regulations, but denied the remainder of the hearing officer's recommendations,

including the issuing of an apology to petitioner. The Commissioner ordered Acadia to

"acknowledge in writing that its policy ...misstates the timing of post-restraint

examination required by the Rights of Recipients," and to amend the policy so it

conforms to those rights. T h s petition f ~ l l o w e d . ~

When the decision of an administrative agency is appealed pursuant to M.R. Civ.

P. 80C, this Court reviews the agency's decision directly for abuse of discretion, errors

of law, or findings not supported by the evidence. Centamore v. Dep't of Human Services,

664 A.2d 369, 370 (Me. 1995). "An administrative decision will be sustained if, on the

basis of the entire record before it, the agency could have fairly and reasonably found

the facts as it did." Seider v. Board of Exam'r of Psychologists, 2000 ME 206 q[ 9, 762 A.2d

551, 555 (Me. 2000) (citing CWCO, Inc. v. Superintendent of Ins., 1997 M E 226, ¶ 6, 703

A.2d 1258,1261 (Me. 1997)). In reviewing the decisions of an administrative agency, the

Court should "not attempt to second-guess the agency on matters falling within its

realm of expertise" and the Court's review is limited to "determining whether the

agency's conclusions are unreasonable, unjust or unlawful in light of the record."

Imagineering v. Sz~perintendentof Ins., 593 A.2d 1050, 1053 (Me. 1991). The focus on

appeal is not whether the Court would have reached the same conclusion as the agency,

Legislation regarding the grievance process and jurisdiction over it changed in April 2004; petitioner was permitted to proceed under the new regulations, even though actions giving rise to her grievance occurred under older laws that would not have permitted her grievance to be heard by DHHS. Petitioner filed a motion to strike Acadia's participation, to which Acadia responded with a motion to intervene. Petitioner ultimately withdrew her objection to Acadia's involvement in the matter. but whether the record contains competent and substantial evidence that supports the

result reached by the agency. CWCO, lnc., 1997 ME 226, 703 A.2d 1258, 1261.

"Inconsistent evidence will not render an agency decision unsupported." Seider, 762

A.2d 551 (citations omitted). The burden of proof rests with the party seelung to

overturn the agency's decision, and that party must prove that no competent evidence

supports the Board's decision. Id. "[Petitioner] must prove that no competent evidence

supports the Board's decision and that the record compels a contrary conclusion."

Bischoffv.Board of Trustees, 661 A.2d 167, 170 (Me. 1995).

Factual determinations must be sustained unless shown to be clearly erroneous.

lmagineering, 593 A.2d at 1053 (noting that the Court recognizes no distinction between

the clearly erroneous and substantial evidence in the record standards of review for

factual determinations made by administrative agencies). "A party seelung review of

an agency's findings must prove they are unsupported by any competent evidence.''

Maine Bankers Ass'n v. Bureal~,684 A.2d 1304,1306 (Me. 1996) (emphasis added).

"When the dispute involves an agency's interpretation of a statute administered

by it, the agency's interpretation, although not conclusive on the Court, is accorded

great deference and will be upheld unless the statute plainly compels a contrary result."

Maine Bankers Assl?z,684 A.2d at 1306 (citing Centamore v. Department of Human Services,

664 A.2d 369,370 (Me. 1995)).

Petitioner's complaint centers on the first few days that she was a patient at

Acadia, October 30, 2002-November 3, 2002. According to regulations, in an

emergency, patients may be given medication involuntarily for up to 72 hours. Any continued emergency medication can only be administered via written authorization of

the clinical director of the facility. While petitioner did not have medication

administered to her beyond the initial 72-hour emergency period, orders were entered to extend that emergency timeframe, without securing the appropriate authorization.

Petitioner was thus under the threat of being involuntarily sedated and restrained.

Blanche C. provided moving testimony about what being restrained was like, with her

doctor testifying at hearing that given the emergency orders (inappropriately) covering

petitioner for almost five days, petitioner could have been so restrained. Petitioner

argues that the regulations were "crystal clear" regarding the need for written

authorization to extend emergency orders, and that those regulations were not obeyed.

Whle the Commissioner agreed with petitioner, the Commissioner concluded that no

harm came to petitioner because no additional medications were involuntarily

administered to petitioner beyond the initial 72-hour authorization period. Petitioner

argues that the harm was the "continuous fear" and "potential state of terror" she and

other patients might be in just knowing that lax interpretation of procedures could

mean involuntary restraint. Petitioner argues that the Commissioner's interpretation of

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Related

Centamore v. Department of Human Services
664 A.2d 369 (Supreme Judicial Court of Maine, 1995)
Hopkinson v. Town of China
615 A.2d 1166 (Supreme Judicial Court of Maine, 1992)
Bischoff v. Board of Trustees
661 A.2d 167 (Supreme Judicial Court of Maine, 1995)
Forbes v. Osteopathic Hospital of Maine, Inc.
552 A.2d 16 (Supreme Judicial Court of Maine, 1988)
Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
CWCO, INC. v. Superintendent of Ins.
1997 ME 226 (Supreme Judicial Court of Maine, 1997)
Maine Bankers Ass'n v. Bureau of Banking
684 A.2d 1304 (Supreme Judicial Court of Maine, 1996)
Isis Development, LLC v. Town of Wells
2003 ME 149 (Supreme Judicial Court of Maine, 2003)
Imagineering, Inc. v. Superintendent of Insurance
593 A.2d 1050 (Supreme Judicial Court of Maine, 1991)
Landmark Realty v. Leasure
2004 ME 85 (Supreme Judicial Court of Maine, 2004)

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