Disability Rights New York v. Office for People with Developmental Disabilities

CourtDistrict Court, E.D. New York
DecidedJune 7, 2024
Docket1:23-cv-03883
StatusUnknown

This text of Disability Rights New York v. Office for People with Developmental Disabilities (Disability Rights New York v. Office for People with Developmental Disabilities) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Disability Rights New York v. Office for People with Developmental Disabilities, (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK DISABILITY RIGHTS NEW YORK, MEMORANDUM & ORDER Plaintiff, 23-CV-3883 (NGG) (SJB) -against- NEW YORK STATE OFFIGE FOR PEOPLE WITH DEVELOPMENTAL DISABILITIES, and KERRI NEIFELD, in her official capacity as Commissioner of the NEW YORK STATE OFFICE FOR PEOPLE WITH DEVELOPMENTAL DISABILITIES, Defendants.

NICHOLAS G. GARAUFIS, United States District Judge. This is a civil rights action brought by Plaintiff Disability Rights New York (“DRNY”) against Defendant New York State Office for People with Developmental Disabilities “OPWDD”) and its Com- missioner, Kerri Neifeld (collectively, “Defendants”). Currently before the court is Defendants’ motion to dismiss for lack of sub- ject matter jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(1). (Not. of Mot. to Dismiss (Dkt, 19); Mem. in Supp. of Mot. to Dismiss (“Defs.’ Mot.”) (Dkt. 20).) For the reasons discussed below, Defendants’ motion is GRANTED. I. BACKGROUND A. Factual Background! Disability Advocates, Inc., d/b/a DRNY is an independent non- profit corporation designated by then-Governor Andrew M. 1 The following facts are taken from the Complaint and, for the purposes of this motion to dismiss, are assumed to be true. See Ark. Pub. Emps. Ret. Sys. v. Bristol-Myers Squibb Co., 28 F.4th 343, 349 (2d Cir. 2022}.

Cuomo as New York Staie’s Protection and Advocacy (“P&A”) system to protect and advocate for persons with disabilities. (Compl. (Dkt. 1) {7 17-19.) Pursuant to this designation and as mandated by federal law, DRNY is authorized to, among other things, investigate incidents of abuse and neglect of persons with disabilities if such incidents are reported to the P&A system. (id. 74 20, 29 (citing 42 U.S.C. § 15043(a) (2) (B)).) Specifically, upon receiving a complaint of abuse or neglect, the Developmental Dis- abilities Assistance and Bill of Rights Act of 2000 (“DD Act”), 42 U.S.C. § 15041 et seq., authorizes the designated P&A system, in this case DRNY, to obtain individual records germane to its in- vestigation of said abuse or neglect. Ud. § 32 (citing 42 U.S.C. 8§ 15043(a)(2)(D and 15043(a)(2)(J)Ci)).) Under the DD Act, DRNY must have access to records within three business days af- ter it makes a written request. Ud. { 33 (citing 42 U.S.C. § 15043(a)(2)() GM; 45 GER. § 1326.25(c)(2)).) Should DRNY’s access to records be delayed or denied, DRNY must be provided with a written statement of reasons for the delay or denial within one business day of the expiration of the deadline to produce the records. (id. € 34 (citing 45 C.F.R. § 1326.26).) New York State law similarly provides DRNY with broad access to the records of persons with disabilities under certain circumstances, including in furtherance of an investigation into alleged abuse or neglect. Ud. 4 36-43 (citing 2022 N.Y. Sess. Laws Ch. 28 (A. 8710) (McKinney) [hereinafter “New York P&A Records Act”]; N.Y. Exec. Law § 558(b)).) In August and September of 2022 respectively, DRNY received two complaints related to two individuals with developmental disabilities that alleged these individuals were left in jail for long periods as a result of OPWDD’s failure to timely remove them from jail and provide necessary care and treatment. Ud. { 44.) New York Criminal Procedure Law mandates that if a local crim- inal court determines that a defendant in a criminal matter lacks

2.

capacity to undergo trial as a result of an intellectual or develop- mental disability, the court must issue an order—known as a “730 Order’—-remanding that individual into Defendants’ cus- tody. GPL. § 730,60(1). Upon receipt of a 730 Order, Defendants must remove the individual from jail and provide them with appropriate care and treatment. Id. (See also Compl. 4 6.) DRNY received complaints that one individual with a develop- mental disability was in jail for over a year after the local criminal court determined he lacked capacity and issued a 730 Order. (Compl. { 45.) Regarding the second individual, the complaint alleged that this person was in jail 33 days after the local criminal court determined he lacked capacity and issued a 730 Order. Ud.) The complaints also alleged that these individuals suffered significant emotional harm and trauma by remaining incarcer- ated and without care or treatment. Ud.) Based on these complaints, as well as others, DRNY initiated an investigation into OPWDD’s practices related to “individuals with developmen- tal disabilities who are in jail, determined to lack capacity for trial, and remanded by criminal courts into Defendants’ custody pursuant to 730 Orders.” Ud. {4 46-47, 50.) As part of its investigation, DRNY sent? Defendants a written re- quest for records pertaining to every individual for whom

2 Plaintiff states this request was sent on April 13, 2023. Gd. 451.) Defend- ants point to evidence submitted by DRNY in support of its now-withdrawn motion for injunctive relief, which reveals that while the letter was dated April 13, 2023, the transmittal email that attached the letter was not sent until 2:41 P.M, on Friday, April 14, 2023. (See Exhibits to Taylor Decl. (Dkt. 7-5) at Bates No. 0001.) See also Amidax Trading Grp. v. S.W.LE.T. SCRL, 671 F.3d 140, 145 (2d Cir. 2011) (“In reviewing a facial attack to the court’s jurisdiction, we draw all facts—which we assume to be true unless contradicted by more specific allegations or documentary evidence—from the complaint and from the exhibits attached thereto.”) (emphasis added).

OPWDD received a C.P.L. § 730.40(1) temporary order of obser- vation or C.P.L. 8 730.50(1) order of commitment since January 1, 2019. Ud. § 51.) Defendants responded three days later, ex- plaining that due to a staffing crisis and the fact that the requested information is “not part of an automated system and will require a manual case-by-case lookup and reconciliation of data across multiple platforms,” there will be a delay in providing the requested records, but that the OPWDD will respond no later than July 14, 2023. (id. 953.) On April 27, 2023, DRNY replied, objecting to the delay, and requesting a meet and confer to dis- cuss resolution. (id. 54.) Rather than meet, OPWDD denied the request, noting that DRNY failed to provide the requisite infor- mation for the request as required by law. Ud. 7 55.) DRNY responded to the Defendants’ denial, explaining that its investi- gation was “prompted by multiple complaints of neglect” and asked to “[t]herefore, please produce the requested records by Friday May 5 to avoid enforcement of our access rights through legal action.” (id. 956.) OPWDD again denied the request, noting that DRNY has yet to identify an individual who has been subject to neglect, provide any evidence of a complaint, nor assert any basis for an investigation. (id. 157; Exhibits to Taylor Decl. (Dkt. 7-5) at Bates No. 0014.) DRNY objected again, noting that absent the requested documents, it will pursue litigation. (Compl.

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Disability Rights New York v. Office for People with Developmental Disabilities, Counsel Stack Legal Research, https://law.counselstack.com/opinion/disability-rights-new-york-v-office-for-people-with-developmental-nyed-2024.