It's hard to win involuntary mental health confinement cases

You can sue the government if it places you in a psychiatric facility against your will, but you have to show the government did not have good reason to do this. That makes these cases hard to win, and the plaintiff in this case loses even if he can prove that one officer lied about the reason for his confinement.

The case is Accardi v. County of Suffolk, a summary order issued on January 14. Plaintiff was hospitalized involuntarily for five days in a psychiatric facility after a series of domestic incidents. Here is the legal framework, from the Mental Health Law:

Under New York law, police officers “may take into custody any person who appears to be mentally ill and is conducting himself or herself in a manner which is likely to result in serious harm to the person or others.” 

Officers may also “direct the removal  of such person or remove him or her to . . . any comprehensive psychiatric emergency program . . . Similarly, officers may take an individual “who appears to be incapacitated by alcohol and/or substances to the degree that there is a likelihood to result in harm to the person or to others . . . to a treatment facility for purposes of receiving emergency services.”

Plaintiff says the County violated the Due Process Clause of the U.S. Constitution (which recognizes such claims) because its officers deliberately misrepresented the facts that influenced the probable cause determination that allowed them to take him to the facility. While plaintiff argued that Defendant Manfredonia told healthcare providers that he had barricaded himself in his home and did not surrender until they completed a four hour negotiation, any such misrepresentation does not matter. Why? Because, the Second Circuit holds, the medical records show plaintiff would have been taken to the facility against his will in any event. The Court of Appeals (Calabresi, Park and Nathan) states

Evidence from Accardi’s medical records confirms that healthcare providers would have decided to involuntarily commit Accardi even without Manfredonia’s alleged statements about a “barricade.” For example, Dr. Narayan wrote that Accardi “has multiple risk factors for completing suicide and homicide, and requires inpatient admission at this time.”  Dr. Narayan also categorized Accardi’s illness as “severe.” Dr. Bonvino noted that Accardi “initially told nursing staff his last drink was about 8 weeks although utox is positive for alcohol”; that Accardi himself reported “he had an argument with his wife, was throwing things, and made the comment that if she left the house he’d kill himself”; and that Accardi was not compliant with his antidepressant medication.

See how hard it is to win cases like this? I think courts will give law enforcement the benefit of the doubt, and the law, through qualified immunity, actually provides a legal framework for that deference, though the Court of Appeals does not reference such immunity in this ruling.