Matter of Rueda v. Charmaine D., 18 N.Y.3d 524 (2012)
An emergency room psychiatrist supervising or treating a patient has standing to seek involuntary commitment under Mental Hygiene Law § 9.27(b)(11), and is not limited to the emergency procedures of Mental Hygiene Law § 9.39.
Summary
Charmaine D. was brought to the emergency room at Jacobi Medical Center. Dr. Shetty, an attending psychiatrist, determined she was acutely agitated and in need of medications and restraints, noting a history of bipolar disorder. Dr. Shetty applied for involuntary admission under Mental Hygiene Law § 9.27. After transfer to Montefiore North Medical Center and confirmation by another doctor, Charmaine was admitted. The director of psychiatry sought a 30-day retention order. Charmaine moved to dismiss, arguing Dr. Shetty lacked standing under § 9.27 and should have proceeded under § 9.39. The Supreme Court denied the motion, and the Appellate Division affirmed. The New York Court of Appeals affirmed, holding that an emergency room psychiatrist does have standing under § 9.27 and is not required to proceed under § 9.39.
Facts
Charmaine D. was taken to the Jacobi Medical Center emergency room.
Dr. Amita Shetty, an attending psychiatrist, found Charmaine acutely agitated and in need of medication and restraints.
Dr. Shetty learned Charmaine had a history of bipolar disorder and prior hospitalizations.
Dr. Shetty concluded Charmaine was paranoid, grandiose, lacked insight and judgment, was unable to care for herself, and posed a potential danger to herself.
Dr. Shetty applied for Charmaine’s involuntary admission under Mental Hygiene Law § 9.27.
The application was supported by certificates from two other examining physicians.
Charmaine was transferred to Montefiore North Medical Center for insurance reasons.
A fourth doctor at Montefiore confirmed Charmaine needed involuntary care and treatment, and she was admitted.
Procedural History
The director of psychiatry at Montefiore North Medical Center petitioned the Supreme Court for a 30-day retention order.
Charmaine moved to dismiss, arguing Dr. Shetty lacked standing under Mental Hygiene Law § 9.27 and should have used Mental Hygiene Law § 9.39.
The Supreme Court denied the motion and ordered Charmaine retained.
The Appellate Division affirmed. Matter of Rueda v Charmaine D., 76 AD3d 443 (1st Dept 2010).
Charmaine appealed to the New York Court of Appeals.
Issue(s)
1. Whether an emergency room psychiatrist-patient relationship is sufficient to grant the psychiatrist standing to seek involuntary commitment under Mental Hygiene Law § 9.27(b)(11)?
2. Whether Dr. Shetty was required to proceed under Mental Hygiene Law § 9.39 rather than § 9.27?
Holding
1. Yes, because the broader reading of the statute better serves its purpose of ensuring that qualified individuals with a sincere and legitimate interest in the patient’s well-being can initiate the commitment process. The statute contains safeguards to protect against ill-founded attempts at commitment.
2. No, because Section 9.27 describes the general procedure for involuntary hospital admissions, while Section 9.39 is a special procedure designed for emergencies. Those seeking commitment are not required to use the emergency procedure when the non-emergency procedure is adequate.
Court’s Reasoning
The Court reasoned that the language of Mental Hygiene Law § 9.27(b)(11) could be read broadly to include emergency room psychiatrist-patient relationships. The court preferred the broader reading to serve the statute’s purpose, which is to identify categories of people likely to have a sincere and legitimate interest in the well-being of the person sought to be committed. The Court found that emergency room psychiatrists are unlikely to abuse the commitment process.
The Court rejected reliance on 14 NYCRR 72.3(g), which defines “treatment” within a specific regulatory context. The Court found no indication that the legislature intended this narrow regulatory definition to apply to Mental Hygiene Law § 9.27(b)(11).
Addressing the argument that Dr. Shetty should have proceeded under Mental Hygiene Law § 9.39, the Court distinguished between the two sections. Section 9.27 provides a general procedure for involuntary admissions, while § 9.39 is designed for emergency situations where immediate action is necessary to prevent harm. The Court noted that § 9.39 requires a showing that the person’s mental illness is likely to result in serious harm to themselves or others, a requirement not found in § 9.27. The court concluded that it would be inconsistent to require use of the emergency procedure when the non-emergency procedure is adequate, noting the irony of Charmaine’s argument that would simultaneously restrict who can make an “application” under 9.27 while arguing the doctor should have proceeded under 9.39 which does not require one.
The Court found that such a requirement would lead to strange results, as a section 9.27 commitment would fail if the patient’s problems were deemed so severe that immediate commitment was needed.