Savastano v. Nurnberg, 77 N.Y.2d 300 (1991)
The procedural scheme allowing the Commissioner of the New York State Office of Mental Health to authorize the transfer of involuntarily committed mentally ill patients from municipal acute-care facilities to state mental health institutions, over their objection, without a prior judicial hearing, does not violate the Due Process Clause.
Summary
This case addresses the constitutionality of transferring involuntarily committed mental patients from municipal hospitals to state-run mental health facilities without a judicial hearing. The plaintiffs argued this violated their due process rights. The New York Court of Appeals held that the existing procedural safeguards, including administrative appeals and the right to challenge the transfer via Article 78 proceedings, adequately protect patients’ rights without necessitating a full judicial hearing before transfer. The court emphasized the medical nature of the transfer decision and the state’s interest in efficient resource allocation.
Facts
Three involuntary patients at Queens Hospital Center, a municipal acute-care facility, were slated for transfer to Creedmoor Psychiatric Center, a state-operated facility. The patients, through the Mental Hygiene Legal Service, objected to the transfers. They argued that the transfer process, lacking a prior judicial hearing, violated their due process rights under the U.S. and New York State Constitutions.
Procedural History
The Supreme Court, Queens County, initially declared the statutory and regulatory scheme unconstitutional. The Appellate Division reversed, finding no violation of due process rights. The plaintiffs then appealed to the New York Court of Appeals.
Issue(s)
Whether the statutory and regulatory scheme permitting the transfer of involuntarily committed mentally ill patients from municipal acute-care facilities to state mental health institutions, over their objection, without a prior judicial hearing, violates the Due Process Clause of the United States and New York State Constitutions.
Holding
No, because the existing administrative procedures, including the right to appeal the transfer decision and seek judicial review through an Article 78 proceeding, provide sufficient due process protections, balancing the patient’s interests with the State’s interests in efficient mental health administration.
Court’s Reasoning
The Court of Appeals applied the balancing test from Mathews v. Eldridge, considering the private interest affected, the risk of erroneous deprivation, and the government’s interest. While acknowledging the patient’s interest in not being inappropriately transferred, the court emphasized that the transfer decision is primarily a medical judgment best left to experts. Quoting Parham v. J.R., the Court stated, “neither judges nor administrative hearing officers are better qualified than psychiatrists to render psychiatric judgments.”
The court found that additional procedural safeguards, such as cross-examination and strict adherence to evidence rules, would not significantly reduce the risk of error. It also rejected the argument that the transferring facility’s potential biases (e.g., overcrowding) invalidate the process, noting the receiving facility’s right to refuse inappropriate transfers. Finally, the court underscored the State’s substantial interest in avoiding the administrative and fiscal burdens of requiring a judicial hearing for every transfer objection. “Such a requirement would, in our view, accomplish little else than the diversion of scarce resources from the care and treatment of mentally ill patients.”
Judge Bellacosa concurred in result only, arguing that the statutory scheme doesn’t implicate a constitutionally cognizable liberty interest.