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

2021 DNH 001
CourtDistrict Court, D. New Hampshire
DecidedJanuary 4, 2021
Docket18-cv-1039-JD
StatusPublished
Cited by2 cases

This text of 2021 DNH 001 (John Doe, et al. v. Commissioner, New Hampshire Department of Health and Human Services) 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, 2021 DNH 001 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

John Doe, et al.

v. Civil No. 18-cv-1039-JD Opinion No. 2021 DNH 001 Commissioner, New Hampshire Department of Health and Human Services

O R D E R

Four individual plaintiffs brought suit, challenging

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 individuals

who experience mental health crises and seek treatment in

hospital emergency rooms.1 The New Hampshire Hospital

Association and twenty hospitals (“the hospitals”) were granted

leave to intervene in the action to bring claims against the

Commissioner.2 The Commissioner moves to dismiss the hospitals’

remaining claims for lack of subject matter jurisdiction,

asserting sovereign immunity under the Eleventh Amendment and a

lack of standing. The hospitals object.

1 The plaintiffs’ action was filed as a putative class action against the Commissioner, and a plaintiff class has now been certified for purposes of the plaintiffs’ federal claim against the Commissioner, Count I.

2 The hospitals have voluntarily dismissed their state law claims, Counts IV and V, without prejudice. Background

The detailed factual background in this case, as alleged in

the hospitals’ amended complaint, was provided in the court’s

order denying the Commissioner’s previous motion to dismiss,

document number 148, and will not be repeated here.

The hospital plaintiffs are the New Hampshire Hospital

Association, Alice Peck Day Memorial Hospital, Androscoggin

Valley Hospital, Catholic Medical Center, Cheshire Medical

Center, Concord Hospital, Cottage Hospital, Elliot Hospital,

Frisbie Memorial Hospital, HCA Health Services of New Hampshire

(Parkland Medical Center and Portsmouth Regional Hospital),

Huggins Hospital, Littleton Hospital Association (Littleton

Regional Healthcare), LRGHealthcare (Franklin Regional Hospital

and Lakes Region General Hospital), Mary Hitchcock Memorial

Hospital, Monadnock Community Hospital, New London Hospital,

Southern New Hampshire Medical Center, Speare Memorial Hospital,

Upper Connecticut Valley Hospital, Valley Regional Hospital, and

Weeks Medical Center. The hospitals name the Commissioner in

her official capacity as the defendant in this case.

The hospitals’ allege that the Commissioner requires the

hospitals to examine, evaluate, and board psychiatric patients,

who are subject to involuntary emergency admission (“IEA”)

certification, until such time as they are transported to a

2 designated receiving facility. The hospitals bring three

federal claims against the Commissioner, pursuant to 42 U.S.C.

§ 1983, alleging that the Commissioner’s practice of boarding

IEA-certified persons in their emergency departments is

violating their constitutional rights.

In Count I, the hospitals allege that the Commissioner’s

boarding practice constitutes an unlawful taking of their

property for public use in violation of the Fifth and Fourteenth

Amendments. In Count II, they allege that the practice

interferes with their possessory rights in their emergency

departments which constitutes an unreasonable seizure of their

property in violation of the Fourth Amendment. In Count III,

they allege that the practice violates their rights to

procedural and substantive due process under the Fourteenth

Amendment by seizing and taking their property and denying them

their fundamental right to use their emergency departments. The

hospital plaintiffs seek a declaration that the Commissioner’s

practice violates their federal constitutional rights and a

permanent injunction against the practice. They also are

requesting nominal damages and attorneys’ fees and costs.

Discussion

The Commissioner moves to dismiss the hospitals’ claims on

the grounds that the claims are barred by sovereign immunity

3 under the Eleventh Amendment and that the hospitals lack

standing to bring the claims. The hospitals object, arguing

that the exception to sovereign immunity provided under Ex Parte

Young, 209 U.S. 123 (1908), applies to their claims. They also

argue that they have standing to bring their claims.

I. Standard of Review

The Commissioner’s motion to dismiss challenges the court’s

subject matter jurisdiction and is brought pursuant to Federal

Rule of Civil Procedure 12(b)(1). Under Rule 12(b)(1), the

court construes the allegations in the complaint liberally,

treats all well-pleaded facts as true, and resolves inferences

in the plaintiffs’ favor. Jalbert v. U.S. Securities & Exchange

Comm’n, 945 F.3d 587, 590-91 (1st Cir. 2019). In addition to

the complaint, the court may consider other evidence submitted

by the parties without objection. Hajdusek v. United States,

895 F>3d 146, 148 (1st Cir. 2018). The plaintiff, as the party

invoking federal jurisdiction, bears the burden of showing that

subject matter jurisdiction exists when challenged by a motion

to dismiss on that ground. Lujan v. Defenders of Wildlife, 504

U.S. 555, 561 (1992).

4 II. Eleventh Amendment

The Commissioner contends that sovereign immunity under the

Eleventh Amendment bars the hospitals’ claims and that the

exception under Ex Parte Young does not apply. Specifically,

the Commissioner argues that the state is the real party in

interest. She also argues that Count III, which alleges a

violation of procedural and substantive due process, is based

solely on allegations that she is violating New Hampshire law.

Further, the Commissioner argues that the Eleventh Amendment

bars the hospital’s claim for nominal damages.

In the absence of consent by the state, the Eleventh

Amendment provides the state immunity from suit brought in

federal court by citizens of that state or another state.

Pennhurst St. Sch. & Hosp. v. Halderman, 465 U.S. 89, 100

(1984). When a state official is sued, the suit is barred if

“the state is the real, substantial party in interest.” Id. at

101. Congress’s enactment of 42 U.S.C. § 1983 did not waive

states’ sovereign immunity to suit in federal court. Spencer v.

N.H. St. Police, 2019 WL 1546995, at *1 (D.N.H. Apr. 9, 2019).

Any waiver of sovereign immunity must be express. Blanchette v.

Tretyakov, 2020 WL 4219787, at *3 (D. Mass. July 23, 2020).

“[A] suit challenging the constitutionality of a state

official’s action is not one against the State.” Pennhurst, 465

U.S. at 102. For that reason, claims for prospective injunctive

5 relief and declaratory judgments to stop an ongoing violation of

federal law by a state official may be brought against the state

official, sued in her official capacity. Va. Office for

Protection & Advocacy v. Stewart, 563 U.S. 247, 255-56 (2011)

(“VOPA”); Ex Parte Young, 209 U.S. at 156. While federal courts

are authorized to require state officials to conform to federal

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
2021 DNH 001, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-et-al-v-commissioner-new-hampshire-department-of-health-and-nhd-2021.