John Doe, et al. v. Commissioner, New Hampshire Department of Health and Human Services, et al.

2020 DNH 070
CourtDistrict Court, D. New Hampshire
DecidedApril 30, 2020
Docket18-cv-1039-JD
StatusPublished
Cited by3 cases

This text of 2020 DNH 070 (John Doe, et al. v. Commissioner, New Hampshire Department of Health and Human Services, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe, et al. v. Commissioner, New Hampshire Department of Health and Human Services, et al., 2020 DNH 070 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

John Doe, et al.

v. Civil No. 18-cv-1039-JD Opinion No. 2020 DNH 070 Commissioner, New Hampshire Department of Health and Human Services, et al.1

O R D E R

The individual plaintiffs filed a putative class action

that challenges practices used by the Commissioner of the New

Hampshire Department of Health and Human Services (“the

Commissioner”) and four New Hampshire hospitals to involuntarily

detain persons who experience mental health crises and seek

treatment in hospital emergency rooms.2 The Commissioner moves

to dismiss the individual plaintiffs’ claims. The plaintiffs

object.

1 Jeffrey A. Meyers was named as the Commissioner of the New Hampshire Department of Health and Human Services (“DHHS”) in the amended complaint, the motion to dismiss, and the objection. In the reply, Kerrin Rounds was identified as the Acting Commissioner of the New Hampshire Department of Health and Human Services. The DHHS website, www.dhhs.nh.gov/ocom/index.htm, states that Lori Shibinette is now the DHHS Commissioner, and she has been automatically substituted as the defendant in this case. Fed. R. Civ. P. 25(d).

2 The New Hampshire Hospital Association and twenty hospitals intervened in the action as plaintiffs and bring claims against the Commissioner of DHHS. The Commissioner’s motion to dismiss those claims is addressed in a separate order. Standard of Review

In considering a motion to dismiss under Federal Rule of

Civil Procedure 12(b)(6), the court accepts the well-pleaded

factual allegations in the complaint as true and construes

reasonable inferences in the plaintiff’s favor. Breiding v.

Eversource Energy, 939 F.3d 47, 49 (1st Cir. 2019). “To

withstand a Rule 12(b)(6) motion, a complaint must contain

sufficient factual matter to state a claim to relief that is

plausible on its face.” Rios-Campbell v. U.S. Dept. of

Commerce, 927 F.3d 21, 24 (1st Cir. 2019) (internal quotation

marks omitted). The plausibility standard requires sufficient

factual allegations “to remove the possibility of relief from

the realm of mere conjecture.” Dumont v. Reily Foods Co., 934

F.3d 35, 44 (1st Cir. 2019) (internal quotation marks omitted).

The purpose of the plausibility standard is to “weed out cases

that do not warrant either discovery or trial.” Rios-Campbell,

927 F.3d at 24 (internal quotation marks omitted).

Background

Four named plaintiffs bring this putative class action,

challenging the practices of the Commissioner with respect to

involuntary emergency admissions of persons with mental illness.

Three of the plaintiffs, John Doe, Charles Coe, and Jane Roe,

have been granted permission to proceed under pseudonyms. The

2 fourth plaintiff, Deborah A. Taylor, is proceeding as the

guardian for her son, Scott Stephen Johnstone.

A. Practice of Psychiatric Boarding

Under New Hampshire law, persons, like the plaintiffs, who

experience mental health crises may be involuntarily admitted on

an emergency basis pursuant to RSA 135-C:27-33. The plaintiffs

allege they and other persons who experience mental health

crises are involuntarily detained in hospital emergency rooms,

pursuant to an IEA petition and certificate, without counsel, a

hearing, or any process for challenging the detention. They

allege that the hospitals are not equipped to provide treatment

while certified persons await admission to designated receiving

facilities.

The plaintiffs allege that on August 21, 2017, there were

seventy-one adults waiting for admission to designated receiving

facilities and that on May 25, 2017, there were twenty-seven

children waiting. Some persons have experienced waiting times

lasting up to four weeks. The plaintiffs further allege that

the Commissioner is aware of the problem but has failed to

correct it.

3 B. Experiences of Individual Plaintiffs

1. John Doe

John Doe was admitted to the emergency room at Southern New

Hampshire Medical Center (“SNHMC”) in Nashua, New Hampshire, on

November 5, 2018, after attempting suicide. SNHMC clinicians on

staff believed that Doe was refusing treatment and, for that

reason, completed a petition and a certificate for involuntary

emergency admission under RSA 135-C:28. Doe contends that the

clinicians were mistaken and that he was willing to be treated

for his mental health issues on an out-patient basis.

After the involuntary emergency admission (“IEA”)

certificate was completed, Doe was detained at SNHMC. SNHMC

renewed the IEA petition on November 8, 2018. After this action

was filed on Doe’s behalf, SNHMC changed Doe’s status to

voluntary admission, and the IEA petition and certificate were

rescinded. He was discharged on November 15, 2018, ten days

after the initial IEA petition and certificate were completed.

Doe did not receive a probable cause hearing during the ten days

of his detention at SNHMC.

2. Charles Coe

Charles Coe’s family brought him to the emergency room at

Concord Hospital on July 20, 2018, because he was experiencing

significant anxiety. Although Coe thought he would be admitted

4 voluntarily, Concord Hospital personnel completed a petition and

an IEA certificate. Coe was placed in the psychiatric ward.

He asked to be released on July 25, but Concord Hospital

refused. Instead, hospital personnel completed another petition

and IEA certificate. Coe then was transferred to a wing of the

hospital for behavioral health emergencies. The hospital

renewed the IEA certificate three times. He was not provided a

probable cause hearing during that time.

Coe hired an attorney who challenged his involuntary

admission by filing a petition for a writ of habeas corpus on

August 3. The hospital released Coe on August 8. Merrimack

County Superior Court issued an order on the habeas petition on

August 9. The court ruled that that if a new IEA petition were

filed as to Coe, he would have to be released or provided a

probable cause hearing within three days pursuant to RSA 135-

C:31, I. Doe v. Concord Hospital, No. 217-2018-CV-00448

(Merrimack Cty. Sup. Ct. Aug. 9, 2018).3

3. Jane Roe

Jane Roe had a contentious interaction with her adult

daughter on September 21, 2018. Her daughter called the police

3 In response to the hospital’s motion for reconsideration, the superior court issued an order on September 5, 2018, holding that the August 9 order had no preclusive effect because Doe’s petition had become moot.

5 and an ambulance. When Roe declined to go with the EMTs, they

injected her with a sedative and took her into custody. She was

taken to the emergency room at St. Joseph’s Hospital and was

involuntarily admitted pursuant to a petition and an IEA

certificate. The certificate was renewed six times through

October 9. Roe did not receive a probable cause hearing while

she was detained at St. Joseph’s Hospital.

Roe was transferred to New Hampshire Hospital on October

10, 2018.

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