Botting v. State of Maine, Dep't of Behavioral and Developmental Servs

CourtSuperior Court of Maine
DecidedMay 31, 2002
DocketKENap-01-52
StatusUnpublished

This text of Botting v. State of Maine, Dep't of Behavioral and Developmental Servs (Botting v. State of Maine, Dep't of Behavioral and Developmental Servs) 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
Botting v. State of Maine, Dep't of Behavioral and Developmental Servs, (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss. CIVIL ACTION DOCKET NO. AP-01-52;

RP KEM- 8 31/09%

TSULA BOTTING, Petitioner

v. DECISION AND ORDER

STATE OF MAINE, DEPARTMENT OF BEHAVIORAL AND DEVELOPMENTAL SERVICES,

Respondent JUN 18 2002

This matter is before the court on petition for review of final agency action pursuant to MLR. Civ. P. 80C and 5 M.R.S.A. § 11001. I. Facts and Procedural History

In May, 1999, Petitioner Tsula Botting was voluntarily admitted to the psychiatric unit of The Aroostook Medical Center (TAMC) following an incident in which she ingested over twelve tablets of Trazodone, an anti-depressant medicine.! While the petitioner was a patient at TAMC, she was treated with a variety of anti-anxiety, anti- depressant and psychotropic medications over a period of eight days. She developed nausea and vomiting in response to the treatments and reports of her behavior stated that she appeared detached and over-sedated. Her physician reduced the petitioner’s medications in response to their adverse impact and her physical symptoms improved. On June 9, 1999, Botting was released from TAMC.

In November, 2000, Botting filed a grievance with TAMC in which she

1 The petitioner was first admitted to the medical unit of the Cary Medical Center in Caribou on the basis of an attempted suicide. Two days after she was admitted, she was transferred for voluntary admission to the Aroostook Medical Center in Presque Isle. It is the petitioner’s course of treatment at The Aroostook Medical Center that forms the basis of this appeal. complained of the inadequacy of the care she received at TAMC and the hospital's failure to obtain proper informed consent before administering various medications to her. Her grievance was filed pursuant to Part A, Sect. VII (G)(9)(a) of the Rights of Recipients of Mental Health Services (RRMHS). 14-193 CMR, ch.1. The RRMHIS is a set of rules promulgated pursuant to the Maine Administrative Procedures Act, 34-B M.R.S.A. § 3003 (1988 & Supp. 2001). They include a guide for grievance procedures for recipients of mental health services who believe that their basic rights have been violated The grievance process follows three sequential levels: Level I requires that a grievance be filed with the supervisor of the unit or program; Level II grievances are addressed by the administrator of the facility and; Level III grievances are appealed to the Commissioner of the Department of Behavioral and Developmental Services (DBDS). RRMHS, Sect. VII(G)(2).

In the petitioner’s Level I grievance she complained of inadequate monitoring of the effects of her medications and failure to inform her about specific medications prescribed for her. Record, Tab 3b. The hospital responded by asserting that the petitioner’s chart showed she was monitored by staff and, further, that the results of hospital patient surveys showed an overwhelming majority were adequately informed of their medical treatments, including the side effects of medication. Id.

On December 6, 2000, petitioner filed a Level II grievance with the chief administrator of TAMC. Id. The CEO responded by reiterating the hospital's conclusions in the Level I grievance response and denying the appeal. Id. On January

2, 2001, petitioner undertook her final administrative step and filed a Level III grievance with the Commissioner of DBDS.?

Following a hearing on February 12, 2001, the DBDS Hearing Officer issued a draft decision in which he found that TAMC had failed to obtain informed consent from the petitioner prior to initiating treatment, but rejected the claim of inadequate medical care and her request for damages. Record, Tab 2. Along with the draft decision, the Hearing Officer issued a draft order requiring TAMC to develop new policies governing patient consent, including a provision allowing input from the petitioner in this process. Id.

The Hearing Officer’s draft decision and order was then reviewed by the Commissioner of DBDS who in turn issued a final order. This order rejected several of the Hearing Officer’s findings and dismissed the petitioner’s grievance. Record, Tab 1. The Commissioner explained in the order that, although the hospital licensure rules of the Department of Human Services (DHS) require that private hospitals with psychiatric units comply with the terms of the RRMHS, DBDS has no independent authority over those facilities. The Commissioner then referred the grievance to the DHS licensing division for further investigation.

Petitioner has filed a timely appeal of the Commissioner’s decision. She claims the decision reflects an erroneous interpretation of the law, constitutes an abuse of discretion and violates her right to due process. She is requesting reinstatement of the hearing officer’s decision, including the portions unfavorable to her position.

II. Standard of review

When an executive agency’s decision is appealed pursuant to MLR. Civ. P. 80C,

2 In January, 2001, the agency was known as the Department of Mental Health, Mental Retardation, and Substance Abuse Services. the court reviews the 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). When the Legislature enacts a statute and entrusts its administration to a particular agency, the court defers to the agency’s interpretation and application of the statute. AFSCME Council 93 v. Maine Labor Rel. Bd., 678 A.2d 591, 593 (Me. 1996) (citing Imagineering , Inc. v. Superintendent of Insurance, 593 A.2d 1050, 1053 (Me. 1991).

III. Discussion

At issue in this case is whether the Commissioner of DBDS has the authority to review a grievance and order a remedy pursuant to RRMHS for a patient who received psychiatric care at a private hospital. The petitioner argues that the Commissioner’s decision to decline jurisdiction vitiates the grievance process and converts it instead into a review of hospital licensing only. She contends that this is neither a suitable remedy for an aggrieved patient, nor what the legislature intended, and that the Commissioner does have the authority to order the remedy recommended by the Hearing Officer, even in the case of private hospital such as TAMC.

Petitioner builds her argument on a series of statutes specific to the provision of mental health services. First she points to the enabling statute which mandates a rulemaking process to protect the rights of “clients receiving services from the department, from any hospital pursuant to subchapter IV or from any program or facility administered or licensed by the department under section 1203-A.” 34-B M.RS.A. § 3003(1). The RRMHS were drafted to comply with this statute. The statute also contains specific provisions requiring that regulations be promulgated to address

grievance procedures and standards for informed consent. 34-B M.R.S.A. § 3003(2)(C), (K). “Client” is defined separately in the statute to include anyone receiving services from an institution falling under the jurisdiction of the department. 34-B M.R.S.A. § 1001(2) (Supp. 2001). “Hospital” under subchapter IV includes non-state mental institutions, and is defined as a “public institution, a private institution or a mental health center, which is administered by an entity other than the State and which is equipped to provide inpatient care and treatment for the mentally ill.” 34-B M.RS.A. § 3801(6).

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