Christy v. Hammel

87 F.R.D. 381, 31 Fed. R. Serv. 2d 1077, 1980 U.S. Dist. LEXIS 15221
CourtDistrict Court, M.D. Pennsylvania
DecidedJune 13, 1980
DocketCiv. No. 79-201
StatusPublished
Cited by11 cases

This text of 87 F.R.D. 381 (Christy v. Hammel) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christy v. Hammel, 87 F.R.D. 381, 31 Fed. R. Serv. 2d 1077, 1980 U.S. Dist. LEXIS 15221 (M.D. Pa. 1980).

Opinion

MEMORANDUM AND ORDER

NEALON, Chief Judge.

I. INTRODUCTION

Plaintiff Lawrence D. Christy is a former inmate of Farview State Hospital, a maximum-security institution located in Wayne County, Pennsylvania. He bases his cause of action on 42 U.S.C. § 1983 and 28 U.S.C. § 1343. The complaint avers that several [384]*384Farview guards handcuffed the plaintiff during an evening in November 1978 and moved him from ward AAII, the second-most privileged section of the hospital, to maximum security (“CCI”).1 This special disciplinary incarceration allegedly lasted six days. Christy charges that he was subjected to the following conditions during his stay at CCI: (1) denial of exercise and recreation, (2) unsanitary living quarters,2 (3) loss of wages, (4) headaches, and (5) weight loss. Furthermore, the plaintiff asserts that upon his release from maximum security he was assigned to Ward AAI, the third-most preferable subdivision at Far-view.

Christy maintains that the defendants violated his Fourteenth Amendment right to due process, because they afforded him neither written notice of the reasons for the move nor a hearing with regard to its propriety. Monetary and injunctive remedies are sought.3 A number of motions are presently pending.

On behalf of the defendants, the Commonwealth has requested that the court either abstain from deciding the underlying constitutional issues or dismiss the suit for failure to state a claim upon which relief can be granted. The plaintiff, conversely, has moved for certification of the case as a class action and an order permitting Kim E. Niehoff, a current resident of Farview, to intervene in the litigation. Upon review of the various arguments presented by the parties, the court will deny the Commonwealth’s dispositive motion and order the class certification on the injunction issue. Niehoff, moreover, shall be allowed to intervene.

II. ABSTENTION

As a general rule, federal courts should refrain from deciding constitutional issues “which might be mooted or presented in a different posture by state court determination of pertinent state law.” Colorado River Water Conservation District v. United States, 424 U.S. 800, 814, 96 S.Ct. 1236, 1244, 47 L.Ed.2d 483 (1976); Railroad Commission of Texas v. Pullman Company, 312 U.S. 496, 498-502, 61 S.Ct. 643, 644-646, 85 L.Ed. 971 (1941).4 The defendants argue that this principle applies to the instant case. A psychiatric patient’s legal rights in Pennsylvania are codified in the Mental Health Procedures Act (“MHPA”), 50 P.S. §§ 7101, et seq. According to the Commonwealth, the state judiciary might interpret the latter statute to guarantee the very procedural protections that Christy claims under the Due Process Clause. Such an interpretation, of course, could eliminate the need to confront the constitutional theory by providing full relief under Pennsylvania law. On this basis, the defendants ask that the court stay its hand until the state judiciary has had an opportunity to construe the MHPA.5

[385]*385The standards for applying the abstention doctrine are delineated in the following passage of D’lorio v. County of Delaware, 592 F.2d 681, 686 (3d Cir. 1978):

. First, there must be uncertain issues of state law underlying the federal constitutional claims brought in the federal court. Second, these state law issues must be amenable to an interpretation by the state courts that would obviate the need for or substantially narrow the scope of the adjudication of the constitutional claims. And third, it must appear that an erroneous decision of state law by the federal court would be disruptive of important state policies. .

It is necessary to determine whether these criteria call for abstention in the instant case.

The first DTorio standard involves the degree of uncertainty in the state issue. Abstention should occur in the instant case only if there exists a real possibility that the MHPA will be interpreted to require the procedural safeguards sought by Christy. If the statute clearly is not susceptible to such a construction, there is no reason to believe that resort to the Pullman rule would evade the constitutional issue. In that event, abstention would be precluded. Wisconsin v. Constantineau, 400 U.S. 433, 438, 91 S.Ct. 507, 510, 27 L.Ed.2d 515 (1971); Harman v. Forssenius, 380 U.S. 528, 534-37, 85 S.Ct. 1177,1181-1183,14 L.Ed.2d 50 (1965). See Field, Abstention in Constitutional Cases: The Scope of the Pullman Abstention Doctrine, 122 U.Pa.L.Rev. 1071, 1088-89 (1974).6 Therefore, initial consideration must turn to the MHPA itself.

According to the Supreme Court of Pennsylvania, the Act resulted from “an enlightened legislative endeavor to strike a balance between the state’s valid interest in imposing and providing mental health treatment and the individual patient’s rights.” In re Gross, 476 Pa. 203, 212, 382 A.2d 116, 121 (1978). The Act governs many aspects of voluntary and involuntary care. Nothing in the statute, however, specifically regulates the disciplining of inmates assigned to facilities such as Farview. The Commonwealth implicitly concedes this fact. The defendants, nevertheless, contend that several sections of the MHPA may be expanded through judicial interpretation to vest involuntary patients with the protections Christy claims. After a careful review of these provisions, the court must disagree.

Section 7306 of the Act7 concerns the transfer of an inmate to an “approved facility.” The provision guarantees the right to a hearing whenever such a move “will constitute a greater restraint” on the patient. The defendants maintain that the principle might be extended to situations such as Christy’s move to maximum security. Close examination of the MHPA undermines this assertion.

[386]*386The scope of § 7306 is clearly limited to a type of transfer quite different from that presently at issue. To qualify for consideration under the provision, a person must be moved to an “approved facility.” The latter term “means any mental health establishment, hospital, clinic, institution, center, day care center, base service unit, community health center, or part thereof, that provides for diagnosis, treatment, care or rehabilitation of mentally ill persons, whether as out patients or in patients.” 50 P.S. § 7103. According to the complaint,8 however, CCI is a place of punishment, not treatment. If the plaintiff’s allegations are correct, the move from AAII to CCI neither had nor was designed to have therapeutic value. Christy’s action, therefore, assumes that the maximum security ward is not a “facility” under the MHPA.

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Bluebook (online)
87 F.R.D. 381, 31 Fed. R. Serv. 2d 1077, 1980 U.S. Dist. LEXIS 15221, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christy-v-hammel-pamd-1980.