Matter of Oceanview Home for Adults, Inc. v. Zucker

2025 NY Slip Op 00805
CourtNew York Court of Appeals
DecidedFebruary 13, 2025
DocketNo. 6
StatusPublished
Cited by1 cases

This text of 2025 NY Slip Op 00805 (Matter of Oceanview Home for Adults, Inc. v. Zucker) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Oceanview Home for Adults, Inc. v. Zucker, 2025 NY Slip Op 00805 (N.Y. 2025).

Opinion

Matter of Oceanview Home for Adults, Inc. v Zucker (2025 NY Slip Op 00805)
Matter of Oceanview Home for Adults, Inc. v Zucker
2025 NY Slip Op 00805
Decided on February 13, 2025
Court of Appeals
Halligan, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided on February 13, 2025

No. 6

[*1]In the Matter of Oceanview Home for Adults, Inc., & c., Appellant,

v

Howard Zucker, & c., Respondent, et al., Respondent.


Michael Y. Hawrylchak, for appellant.

Gary J. Malone, for respondent Howard Zucker, & c.



HALLIGAN, J.

The State of New York's Department of Health (DOH) licenses certain facilities known as "adult homes" to provide "long-term care, room, board, housekeeping, personal care and supervision to five or more adults unrelated to the operator" (Dept of Health Regs [18 NYCRR] § 485.2 [b]). Regulations promulgated by DOH provide that an adult home may not admit additional residents with serious mental illness if it has a capacity of 80 or more beds and its resident population is over 25% persons with serious mental illness (id. § 487.4 [d]; see also id. § 487.2 [c]). Oceanview Home for Adults, Inc., an adult home subject to this admissions cap, claims that those regulations discriminate against persons with disabilities in violation of the Fair Housing Act Amendments of 1988 (FHAA), which extended the protections of the Fair Housing Act (FHA) to persons with disabilities (see 42 USC § 3604 [f] [1]-[2]). We conclude that plaintiff has failed to establish that the challenged regulations facially discriminate against persons with disabilities, and therefore affirm.

I.

We begin with a brief history of the challenged regulations. In 1999, the United States Supreme Court held in Olmstead v L.C. ex rel. Zimring that the Americans with Disabilities Act (ADA) required Georgia to move two individuals whose psychiatrists had determined they were fit for "community placement" from institutional housing into a community setting, reasoning that "[u]njustified isolation . . . is properly regarded as discrimination based on [*2]disability" under the ADA (527 US 581, 587, 593-595, 597 [1999]). The Court noted Congress's findings that "historically, society has tended to isolate and segregate individuals with disabilities," and that "individuals with disabilities continually encounter various forms of discrimination, including . . . segregation" (id. at 600, citing 42 USC § 12101 [a] [2], [a] [5]). It concluded that the ADA imposes an affirmative obligation on the states to prevent the segregation of persons with disabilities in institutionalized settings that are more restrictive than appropriate for their needs (id. at 597-603). Related regulations promulgated by the Department of Justice (DOJ) pursuant to the ADA require that "[a] public entity shall administer services, programs, and activities in the most integrated setting appropriate to the needs of qualified individuals with disabilities" (28 CFR 35.130 [d]).

Following Olmstead, a number of courts held that the ADA and its implementing regulations impose a broad "integration mandate" on the states, which is violated by "[a] failure to provide placement in a setting that enables disabled individuals to interact with non-disabled persons to the fullest extent possible" (e.g. Joseph S. v Hogan, 561 F Supp 2d 280, 289-290 [ED NY 2008] [internal quotation marks omitted], citing Messier v Southbury Training Sch., 1999 WL 20910 at *9 [D Conn Jan. 5, 1999]; see also Helen L. v DiDario, 46 F3d 325, 335-336 [10th Cir 1995]). This integration mandate has underpinned various challenges to state policies or practices that contribute to the segregation of the mentally ill (see Steimel v Walmart, 823 F3d 902, 910-914 [7th Cir 2016] [plaintiffs alleged that change in Indiana's provision of Medicaid services would reduce their ability to participate in community activities]; Guggenberger v Minnesota, 198 F Supp 3d 973, 1026-1030 [D Minn 2016] ["the integration mandate's application is not limited to the context of institutionalization"]; Lane v Kitzhaber, 841 F Supp 2d 1199, 1205 [D Or 2012] [allegations concerning segregation in employment facilities]), including practices which create an undue risk of institutionalization (see M.R. v Dreyfus, 697 F3d 706, 720 [9th Cir 2012]; Fisher v Oklahoma Health Care Auth., 335 F3d 1175 [10th Cir 2003]; Hiltibran v Levy, 793 F Supp 2d 1108 [WD Mo 2011]).

In 2009, a federal court held that DOH's licensing regime governing adult homes violated the ADA as applied to persons with mental illness (Disability Advocates, Inc. v Paterson, 653 F Supp 2d 184, 187-188 [ED NY 2009] [hereinafter DAI]). The DAI lawsuit was targeted at "adult homes in New York City with more than 120 beds and in which twenty-five residents or 25% of the resident population (whichever is fewer) have a mental illness" (id. at 187). After a lengthy trial, the federal district court concluded that "virtually all" members of the subject group ("people with mental illness residing in, or at risk of entry into" the targeted adult homes) were "qualified" to receive mental health services in the more integrated setting of "supported housing" (id. at 187-188). The court further determined that the large adult homes at issue contributed to the segregation of persons with mental illness by limiting their opportunities to interact with persons without mental illness, discouraging them from integrating into the community, and fostering "learned helplessness" (id. at 208-216). Although the trial court's decision in DAI was vacated by the Second Circuit on standing grounds, the Second Circuit recognized that litigation might continue (675 F3d 149, 152, 162 [2d Cir 2012]).

The regulations at issue here were promulgated around this time. In August and October of 2012, the Chief Medical Officer of the State's Office of Mental Health (OMH) issued two Clinical Advisories stating that certain large adult homes, known as transitional adult homes, "result in housing experiences that are not clinically appropriate to the needs of such persons and are not conducive to their rehabilitation or recovery" (Lloyd I. Sederer, Clinical Advisory, at 1 [Aug. 8, 2012], available at https://omh.ny.gov/omhweb/advisories/; see also Lloyd I. Sederer, UPDATE — Clinical Advisory Regarding Adult Homes Previously Issued to Psychiatric Inpatient Programs on August 8, 2012 [Oct. 1, 2012], available at https://omh.ny.gov/omhweb/advisories/). Shortly thereafter, DOH issued the challenged regulations, which defined a "transitional adult home" as an adult home with a bed capacity of 80 or more residents and with a proportion of 25% or more of the resident population having "serious mental illness" (see 18 NYCRR § 487.13 [b] [1]). The regulations prohibited these facilities from admitting any persons with serious mental illness until and unless the proportion of the resident population with serious mental illness fell below the 25% threshold (id.

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Matter of Oceanview Home for Adults, Inc. v. Zucker
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