CROSSON v. NORTHERN LIGHT SEBASTICOOK VALLEY HOSPITAL

CourtDistrict Court, D. Maine
DecidedJune 6, 2025
Docket1:25-cv-00230
StatusUnknown

This text of CROSSON v. NORTHERN LIGHT SEBASTICOOK VALLEY HOSPITAL (CROSSON v. NORTHERN LIGHT SEBASTICOOK VALLEY HOSPITAL) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CROSSON v. NORTHERN LIGHT SEBASTICOOK VALLEY HOSPITAL, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE KIMBERLY D. CROSSON, ) ) Plaintiff ) ) v. ) 1:25-cv-00230-LEW ) NORTHERN LIGHT SEBASTICOOK ) VALLEY HOSPITAL, et al., ) ) Defendants ) RECOMMENDED DECISION AFTER REVIEW OF PLAINTIFF’S COMPLAINT Plaintiff filed a complaint and an application to proceed without prepayment of fees, which application the Court granted. (Complaint, ECF No. 1; Application, ECF No. 2; Order, ECF No. 10.)1 Because the Court granted Plaintiff leave to proceed without prepayment of fees, a preliminary review of Plaintiff’s complaint is appropriate. 28 U.S.C. § 1915(e)(2). Following a review of Plaintiff’s complaint, I recommend the Court dismiss the complaint. FACTUAL ALLEGATIONS2 In December 2023, Plaintiff was in her vehicle on her way to obtain medical services related to her pacemaker when a truck side swiped her vehicle. Plaintiff drove some

1 Plaintiff originally filed the complaint in the District of Massachusetts, but due to lack of venue, the case was transferred to the District of Maine. (Order, ECF No. 6.) 2 For purposes of this review, the facts are derived from Plaintiff’s complaint and supporting attachments, and the alleged facts are viewed most favorably to Plaintiff. distance to look for a safe location and to obtain assistance. A local police officer arrived and inquired about the absence of a license plate on Plaintiff’s vehicle. The officer also

looked into her vehicle. Plaintiff gave the officer the vehicle registration, and the officer advised that she could sit in her car for a minute. Plaintiff responded that she was going to a place with phone service and started to walk toward a nearby house. Another police unit arrived while Plaintiff was in the driveway of the house and placed her in handcuffs. The officer subsequently removed the handcuffs and drove her back to her car. State police, who had also arrived at Plaintiff’s vehicle, transported her to a local hospital.

At the hospital, Plaintiff provided certain information and her identification card to the receptionist. When Plaintiff exited the hospital, the receptionist and a security guard followed her. After she reentered the hospital, staff members and medical providers monitored her and began to conduct a psychological evaluation without Plaintiff’s knowledge. Plaintiff then attempted to leave, but she was not permitted to do so. At some

point thereafter, three staff members arrived in a hospital van and transported Plaintiff to her home. Plaintiff maintains that the hospital personnel did not assist her, including by providing her with the name of a relevant organization or advocate. Instead, she was stereotyped, harassed, and her privacy was violated. Plaintiff named as defendants the

hospital, the hospital’s president, the hospital’s parent company, and another company, and an insurer. Plaintiff also listed unknown John and Jane Doe defendants as placeholders for hospital staff members. LEGAL STANDARD 28 U.S.C. § 1915 is designed to ensure meaningful access to the federal courts for individuals unable to pay the cost of bringing an action. When a party is proceeding

without prepayment of fees, however, “the court shall dismiss the case at any time if the court determines,” inter alia, that the action is “frivolous or malicious” or “fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2)(B). “Dismissals [under § 1915] are often made sua sponte prior to the issuance of process, so as to spare prospective defendants the inconvenience and expense of answering such complaints.” Neitzke v.

Williams, 490 U.S. 319, 324 (1989). “A self-represented plaintiff is not exempt from this framework, but the court must construe his complaint ‘liberally’ and hold it ‘to less stringent standards than formal pleadings drafted by lawyers.’” Waterman v. White Interior Sols., No. 2:19-cv-00032- JDL, 2019 WL 5764661, at *2 (D. Me. Nov. 5, 2019) (quoting Erickson v. Pardus, 551

U.S. 89, 94 (2007)). “This is not to say that pro se plaintiffs are not required to plead basic facts sufficient to state a claim.” Ferranti v. Moran, 618 F.2d 888, 890 (1st Cir. 1980). DISCUSSION “‘Federal courts are courts of limited jurisdiction,’ possessing ‘only that power authorized by Constitution and statute.’” Gunn v. Minton, 568 U.S. 251, 256 (2013) (quoting Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 377 (1994)). “It

is to be presumed that a cause lies outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Kokkonen, 511 U.S. at 377 (citation omitted). “A court is duty-bound to notice, and act upon, defects in its subject matter jurisdiction sua sponte.” Spooner v. EEN, Inc., 644 F.3d 62, 67 (1st Cir. 2011). For the matter to proceed in this Court, Plaintiff’s claim must present either a federal

question, 28 U.S.C. § 1331, or a matter in controversy that exceeds the value of $75,000 between persons domiciled in different states, 28 U.S.C. § 1332. Pursuant to § 1331, federal district courts “have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. By alleging that Defendants’ conduct violated the United States Constitution, Plaintiff evidently attempts to invoke the Court’s federal question jurisdiction. On the civil

cover sheet, Plaintiff identified “federal question” as a basis for jurisdiction. The Court’s jurisdiction over any possible federal claim based on a constitutional deprivation would be governed by 42 U.S.C. § 1983. Section 1983 provides that [e]very person who, under color of any statute, ordinance, regulation, custom, or usage, of any State ... subjects, or causes to be subjected, any citizen of the United States ... to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured . . . . As the plain language of § 1983 reflects, a claim for the deprivation of a constitutional right must be based on the conduct of a state actor. Estades-Negroni v. CPC Hosp. San Juan Capestrano, 412 F.3d 1, 4 (1st Cir. 2005). Plaintiff has not alleged any facts that would support a finding that the medical entities or individuals named as defendants are government agencies or employees.3

3 To the extent that the psychological assessment that was allegedly performed without Plaintiff’s consent can be construed to be part of an involuntary commitment process, Defendants would not be considered state actors. The First Circuit has held in similar cases that private hospitals and medical staff who participate in involuntary commitment proceedings are not thereby transformed into state actors. Id.

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Related

Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Rodriguez-Bruno v. Doral Mortgage
57 F.3d 1168 (First Circuit, 1995)
Spooner v. EEN, INC.
644 F.3d 62 (First Circuit, 2011)
David R. Ferranti v. John J. Moran
618 F.2d 888 (First Circuit, 1980)
Gladys L. Cok v. Family Court of Rhode Island
985 F.2d 32 (First Circuit, 1993)
Susan Rockwell v. Cape Cod Hospital
26 F.3d 254 (First Circuit, 1994)
Gunn v. Minton
133 S. Ct. 1059 (Supreme Court, 2013)
United States v. Bynum
508 F.3d 1134 (Eighth Circuit, 2007)

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Bluebook (online)
CROSSON v. NORTHERN LIGHT SEBASTICOOK VALLEY HOSPITAL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crosson-v-northern-light-sebasticook-valley-hospital-med-2025.