Hovis v. County of Lebanon

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 12, 2025
Docket1:24-cv-00355
StatusUnknown

This text of Hovis v. County of Lebanon (Hovis v. County of Lebanon) 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
Hovis v. County of Lebanon, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA GREGORY HOVIS, : Civil No. 1:24-CV-00355 : Plaintiff, : : v. : : COUNTY OF LEBANON, et al., : : Defendants. : Judge Jennifer P. Wilson MEMORANDUM Before the court is the motion to dismiss filed by one group of defendants in this case, Defendants Thomas Long (“Long”) and County of Lebanon (“County”). (Doc. 44.) Defendants Long and County seek to dismiss the second amended complaint filed by Plaintiff Gregory Hovis (“Hovis”) which, with respect to Defendants Long and County, alleges that Hovis was denied due process during his involuntarily civil commitment as a result of Defendant Long’s investigation, legal advice, and dereliction of his responsibilities as a minister of justice in the context of the civil commitment. (Doc. 42.) For the reasons that follow, the motion will be granted. FACTUAL BACKGROUND AND PROCEDURAL HISTORY In the second amended complaint, Hovis alleges that on March 1, 2022, Hovis was speaking with his wife in his home “in hopes of reconciling their marriage.” (Doc. 42, ¶ 20.) This conversation, however, was not in good faith because “rather than actually attempting to reconcile the marriage, Plaintiff’s wife and her brother had concocted a plan whereby she would send a text message to

him [her brother] and he would alert the police to a ‘dangerous situation’ in hopes that they would arrive and either arrest or kill Plaintiff.” (Id. ¶ 21.) Hovis’ wife sent the message and Troopers were dispatched to the house. (Id. ¶¶ 22, 23.)

Upon arrival, the Troopers found Hovis’ wife already outside of the home and then observed Hovis leave his home “without incident.” (Id. ¶ 24.) At this time, Hovis was “lawfully carrying a handgun in his back pocket[,]” and he “made no furtive movements or gave any indication he intended to harm (or had harmed) himself or

anyone else.” (Id. ¶¶ 25, 26.) The Troopers gave commands to Hovis, and he attempted to comply. (Id. ¶ 27.) However, at this time, the Troopers “physically assaulted Plaintiff, took him

to the ground, handcuffed him, and secured him in the back of a State Police patrol vehicle.” (Id. ¶ 28.) Hovis’ hands were restrained, and the Troopers searched his person and seized his handgun. (Id. ¶¶ 29, 31.) Hovis “became distraught by the interaction and subsequent arrest.” (Id. ¶ 30.) Hovis was then “transported to

Gettysburg Hospital, against his will, for initial evaluation and then taken to WellSpan Philhaven Hospital where he was involuntarily committed under § 302 of the Mental Health Procedures Act of Pennsylvania.”1 (Id.¶ 32.)

After Plaintiff was transported to WellSpan Philhaven in Lebanon County, Pennsylvania, Defendant Thomas S. Long (“Long”), the Lebanon County Solicitor, “investigated Plaintiff’s mental [h]ealth.” (Id. ¶ 33.) Allegedly, “Plaintiff did not

have an ongoing mental health issue and the video of the incident would have demonstrated to Long that Plaintiff did not need to be committed.” (Id. ¶ 34.) At this time, “Long provided advice to Dr. Qasim2 about extending the civil commitment of Plaintiff and was involved in the petition documents signed by Dr.

Qasim in support of the § 303 extension.”3 (Id. ¶ 37.)

1 The Pennsylvania Mental Health Procedures Act (“MHPA”) provides for involuntary emergency examination and treatment for a period not to exceed 120 hours “upon the certification of a physician stating the need for such examination; or upon a warrant issued by the county administrator authorizing such examination; or without a warrant upon application by a physician or other authorized person who has personally observed conduct showing the need for such examination.” 50 P.S. § 7302. This procedure and section of the MHPA will be referred to in this memorandum as “§ 302.”

2 Dr. Qasim is a licensed physician who is employed at WellSpan Philhaven and “was the doctor charged with evaluating and signing a verified charge against Plaintiff for Defendant County of Lebanon.” (Doc. 42, ¶ 14.)

3 The MHPA provides that “[a]n application for extended involuntary emergency treatment may be made for any person who is being treated pursuant to section 302 whenever the facility determines that the need for emergency treatment is likely to extend beyond 120 hours.” 50 P.S. § 7303. This application is commonly known as a “§ 303” application or petition. After a § 303 petition is filed, a person subject to the petition is entitled to the appointment of counsel and review by a judge or mental health review officer. Id. § 7303(c). There is also a right to petition the Pennsylvania Court of Common Pleas for review. Id. § 7303(g). The extended involuntary commitment shall end “[w]henever a person is no longer severely mentally disabled or in need of immediate treatment” or after twenty days, unless the person is admitted to voluntary treatment, or a court extends the involuntary treatment pursuant to section 304. Id. § 7303(h). Hovis had a hearing in front of a mental health review hearing officer on March 4, 2022. (Id.) At the hearing, Defendant Long represented Lebanon County

and “prosecuted the civil commitment action against Plaintiff.” (Id. ¶ 38.) During the hearing: Long relied on (a) hearsay testimony4 by Trooper Careiro [sic] which was inconsistent with video evidence possessed by Pennsylvania State Police and, on information and belief, Long and Lebanon County, and (b) testimony by Samir Qasim who, despite admitting Plaintiff did not presently pose a threat to himself or others, forcefully advocated for continued detention of Plaintiff through extended involuntary commitment pursuant to §303 of the Mental Health Procedures Act of Pennsylvania. (Id. ¶ 39.) The hearing officer found that further involuntary commitment was warranted “despite complete lack of evidence[.]” (Id. ¶ 40.) Hovis was “released” after an unknown amount of time following his filing a petition for review with the Court of Common Pleas. (Id. ¶ 42.) Hovis alleges that “at the hearing before [Court of Common Pleas Court] Judge Kline, [Long] made clear that this was ‘all about gun’ and sought only to justify the conduct of the County and Dr. Qasim rather than to ensure the rights of Hovis[.]” (Id. ¶ 66.) Relevant to Defendant Long, the second amended complaint contains one count for violation of 42 U.S.C. § 1983. (Id. ¶¶ 61–72.) The count alleges that

4 The court notes that, in a hearing pursuant to § 303, “[t]he judge or mental health review officer may review any relevant information even if it would be normally excluded under rules of evidence if he believes that such information is reliable.” 50 P.S. § 7303(c). Long “unreasonably and improperly investigated” Hovis’ mental health prior to “the establishment of any need for civil commitment[,]” and Long gave “improper

legal advice to Dr. Qasim and the facility” to “validate and give apparent legitimacy to the wrongful actions of the PSP Troopers[.]” (Id. ¶ 63.) Hovis also alleges that during his investigation, Long learned that “Hovis was not perceived to

be a threat to himself or others, but additional detention was only considered to provide Defendant Qasim more time.” (Id. ¶ 64.) Hovis alleges he was denied due process “because of [Long’s] dereliction of Pa. R. Prof. Conduct 3.8 and [Long’s] responsibilities thereunder, specifically in his essential role of minister of justice.”

(Id. ¶ 65.) Hovis alleges that “the failed and faulty investigation by Defendant Long and improper legal advice by Defendant Long to Defendant Qasim constitute unreasonable procedures for evaluating whether a § 303 commitment should be

pursued.” (Id.

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Bluebook (online)
Hovis v. County of Lebanon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hovis-v-county-of-lebanon-pamd-2025.