Thursday, January 21, 2010

Involuntary commitment case survives technical dismissal

It's hard to get excited about the Rooker-Feldman doctrine in federal court. Rooker-Feldman is named after two Supreme Court cases which stand for the proposition that you can't file a federal lawsuit which would have the effect of overturning a state court judgment. Boring, but important.

The case is Morrison v. City of New York, decided on January 11. Rooker-Feldman may be both boring and important, but it also doesn't apply that often. Not since the Supreme Court reigned in Rooker-Feldman a few years ago in Exxon Mobil Corp. v. Saidi Basic Indus. Corp., 544 U.S. 280 (2005). As the Second Circuit says, "the Supreme Court clarified the scope of the doctrine, explaining that it was 'confined' to 'cases brought by state-court losers complaining of injuries caused by state court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."

In Morrison, after she was seen chanting and engaging in highly emotional prayer outside the Family Court which had taken up child neglect proceedings against her, the plaintiff was ordered by a Family Court judge to undergo a psychiatric evaluation. Doctors at the hospital decided there was reasonable cause to believe that Morrison had a mental illness and she was therefore kept at the hospital for two weeks against her will before she was let go. She then sued the doctors under Section 1983.

The district court dismissed the case under Rooker-Feldman, reasoning that the federal case was really a challenge to the family court order and that the doctors had no choice under that order to detain Morrison. The Court of Appeals (Jacobs, Walker and Leval) reverses. Looking at things in the light most favorable to Morrison, the family court order was unclear and it is by by no means certain that the doctors detained her at the hospital under court order. Instead, we may infer that the doctors detained her on their own judgment, which Morrison challenges. The Court says:

As between the two competing interpretations of the ambiguous Family Court order, we find the Plaintiff’s interpretation far more reasonable than the Defendants’. Admittedly, if the court order had specified what Defendants contend it means – that the hospital was ordered to detain Plaintiff for two weeks regardless of whether any medical justification was found for doing so – Defendants would have a strong argument that Plaintiff’s challenge to her two-week detention must be viewed as a challenge to the court order that directed it, and thus barred by Rooker-Feldman. But the order did not specify that the hospital was to detain her for two weeks regardless of whether it found medical cause to do so. And in our view it is not reasonable either to give it that interpretation or to assume that the Elmhurst doctors would have so interpreted it, especially in view of (a) the fact that such an order would have violated New York law and (b) evidence that neither the judge nor the doctors so understood it.

Morrison's case survives the Rooker-Feldman challenge. She can now go after the medical judgments which locked her in the hospital for two weeks. The "takeaway" from this case (to use a modern buzzword) is not only that Rooker-Feldman has limited application, but that the courts need to very closely review the lawsuit in determining whether the case violates Rooker-Feldman.

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