Commonwealth ex rel. Brown v. Cleaver

43 Pa. D. & C.3d 367, 1981 Pa. Dist. & Cnty. Dec. LEXIS 3
CourtPennsylvania Court of Common Pleas, Chester County
DecidedDecember 18, 1981
Docketno. 309 P Miscellaneous 1980
StatusPublished

This text of 43 Pa. D. & C.3d 367 (Commonwealth ex rel. Brown v. Cleaver) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Chester County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth ex rel. Brown v. Cleaver, 43 Pa. D. & C.3d 367, 1981 Pa. Dist. & Cnty. Dec. LEXIS 3 (Pa. Super. Ct. 1981).

Opinion

MARRONE, P.J.,

— This matter is currently before the court on defendant’s appeal from our order of July 17, 1981, which transferred defendant from Norristown State Hospital to Farview State Hospital pursuant to section 306 of the Mental Health Procedures Act, Act of July 9, 1976, P.L. 817, (hereinafter Mental Health Procedures Act), 50 P.S. §7306.

On October 22, 1977, a complaint was filed charging defendant with criminal homicide. A hearing was conducted on June 21, 1979, to determine whether defendant was competent to stand trial and whether defendant was legally responsible for his actions. On June 22, 1979, the Honorable John M. Wajert entered an order absolving defendant of criminal responsibility for the homicide. Defendant was then returned to Norristown State Hospital.

On May 29, 1981, Ann Cleaver, Acting Superintendent of the Norristown State Hospital, petitioned the court to transfer defendant to Farview State Hospital because of recent serious threats to hospital personnel, other patients and property. Susan J. Gilhooly, Esq., Mental Health Review Officer, conducted a hearing on June 16, 1981, and filed a written report recommending the transfer. On June 29, 1981, the .Honorable Lawrence E. Wood adopted the master’s recommendation and ordered defendant transferred to Farview State Hospital.

Defendant’s counsel presented Judge Wood with a petition and rule for review of the certification. Judge Wood issued the rule with a return date but, as is customary in this county, did not set a hearing date. Petitioner failed to take the petition to the [369]*369court administrator’s office to procure the hearing date, which is the procedure followed in Chester County for all petitions that require a hearing. Counsel brought the failure to schedule a hearing to the attention of the court and a hearing was scheduled within 72 hours of that notice.

At the hearing, testimony was presented by Doctors Jorge Pirori, Paul A. Grayce, and Leo C. Freeman, as well as two psychiatric security aides and defendant’s mother. At the conclusion of the hearing the court entered an order affirming the master’s recommendation.

Defendant’s appeal raised three issues. First, that the court should have dismissed the petition because a hearing to review the master’s certification was not conducted within 72 hours; secondly, that the petition should be dismissed because section 406 of the Mental Health Procedures Act, 50 P.S. §7406 is unconstitutionally vague; and finally, that finding that defendant is “potentially dangerous” does not fulfill the requirements of section 306 of the Mental Health Procedures Act, 50 P.S. §7306.

Section 109(b) of the Mental Health Procedures Act, 50 P.S. §7109(b) provides that a person made subject to treatment upon the recommendation of a mental health review officer may, as a matter of right, request review of the recommendation by the court of common pleas. Furthermore, the statute requires that a hearing be scheduled within 72 hours after the petition for review is filed unless a continuance is requested by the person’s counsel. The well-established procedure in Chester County is for petitioner to present his petition and rule to the signing judge for that week. If the judge approves the rule and signs it, petitioner must then transmit the petition and rule to the court administrator’s office where the date and time for the hearing is obtained. [370]*370Having all hearings scheduled by a central office permits the court to fairly distribute the workload among all the members of the bench and to take into consideration available courtroom space and previously scheduled trials or hearings. In the instant matter petitioner’s attorney failed to follow this procedure and as a result no hearing was scheduled. Furthermore, his petition was initially filed in the clerk of court’s. office rather than the prothonotary’s office. Since the failure to properly schedule the hearing occurred as a result of the defense counsel’s own actions we properly refused the request to dismiss on this ground.

Defendant’s statement of matters complained of on appeal alleges that section 406(c) of the Mental Health Procedures Act, 50 P.S. § 7406(c) is unconstitutionally vague. We presume that the statement intended to challenge the constitutionality of section 306(c) because there is no section 406(c).

Section 306(c) of the Mental Health Procedures Act, 50 P.S. §7306(c) provides that a transfer to a facility imposing greater restraint on the patient shall not occur unless a judge or mental health review officer has found such transfer to be “necessary and appropriate.”

There are two principal grounds for concluding that a statute is unconstitutionally vague; first,,if it fails to provide adequate warning of conduct proscribed by the statute; and secondly, if it fails to provide standards restricting the discretion of governmental authorities or courts enforcing the statute. Commonwealth ex rel Finken v. Roop, 234 Pa. Super. 155, 339 A.2d 764 (1975).

We begin with the proposition that a statute challenged as vague is presumptively constitutional and will not be declared unconstitutional unless it clear[371]*371ly, palpably and plainly violates the United States Constitution or the Constitution of the Commonwealth of Pennsylvania. Single v. Sheppard, 464 Pa. 387, 346 A.2d 897 (1975); Sinder v. Shapp, 45 Pa. Commw. 337, 405 A.2d 602 (1979). Under this standard we find section 306(c) of the Mental Health Procedures Act to be constitutional.

Section 306(c) does not result in the original deprivation of liberty or freedom. That determination has already been made under the applicable provisions of the Mental Health Procedures Act. What is at issue in the instant matter is the transfer of a patient already subject to the restraints imposed by the Mental Health Procedures Act to a facility with greater security and -restraint.

We interpret “necessary and appropriate” to • mean that in the opinion of the treating medical staff, such a transfer is required to effectuate the recommended level of supervision and treatment of the patient for the purpose of preventing injury to the patient being transferred, other patients or facility staff. The transfer is necessary and appropriate if the patient cannot be safely treated in the less restricted, facility.

In the instant case, Dr. Jorge Priori testified that he requested the transfer to a maximum-security institution because of an escalation of Mr. Brown’s violent behavior, which was not controllable through the use of medications. The staff considered Mr. Brown a more dangerous individual than any of the other patients at the facility. Furthermore, Norristown State Hospital, being a medium-security facility, did not have the type of facilities required to treat violent patients for extended periods of time. Only maximum-security institutions are equipped to treat violent patients. Under the cir.cumstances of the present case, we find that it was [372]*372clearly “necessary and appropriate” that the patient by transferred to a more restrictive facility.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Snider v. Shapp
405 A.2d 602 (Commonwealth Court of Pennsylvania, 1979)
Commonwealth Ex Rel. Finken v. Roop
339 A.2d 764 (Superior Court of Pennsylvania, 1975)
Singer v. Sheppard
346 A.2d 897 (Supreme Court of Pennsylvania, 1975)

Cite This Page — Counsel Stack

Bluebook (online)
43 Pa. D. & C.3d 367, 1981 Pa. Dist. & Cnty. Dec. LEXIS 3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-ex-rel-brown-v-cleaver-pactcomplcheste-1981.