Mental Hygiene Legal Services v. Wack, 75 N.Y.2d 751 (1989)

Mental illness, as defined in Mental Hygiene Law § 1.03 (20), includes conditions manifesting in disorders of behavior, feeling, thinking, or judgment requiring care, treatment, and rehabilitation, even if an effective treatment is elusive; retention in a mental health facility is permissible if the individual requires further in-patient care.

Summary

This case addresses the standard for retaining an individual in a mental health facility under New York’s Mental Hygiene Law. Angel Cruz, who had previously been found not guilty by reason of mental disease or defect for murder, sought release via habeas corpus. The Supreme Court initially ordered his release, finding he was no longer mentally ill. The Appellate Division reversed in part, finding he was no longer dangerously mentally ill but still required retention, albeit in a non-secure facility. The Court of Appeals affirmed the Appellate Division, holding that the evidence supported the need for continued in-patient care, even if the individual’s own expert disagreed with the label of ‘mental illness’.

Facts

• Angel Cruz was committed to a secure psychiatric facility in 1979 after being found not guilty by reason of mental disease or defect for murdering his common-law wife and stepson.
• Cruz was initially diagnosed with paranoid schizophrenia.
• In this proceeding, the Supreme Court ordered Cruz’s release, finding he was no longer mentally ill.
• Psychiatric experts, including Cruz’s own expert, testified that Cruz continued to suffer from severe antisocial and paranoid personality disorders.
• All experts recommended continued retention in some level of custody within the state’s mental hygiene system.

Procedural History

• Cruz filed a habeas corpus proceeding pursuant to Mental Hygiene Law § 33.15, seeking release.
• The Supreme Court ordered his release.
• The Appellate Division reversed in part, finding Cruz no longer dangerously mentally ill but still in need of retention in a non-secure facility.
• The Court of Appeals affirmed the Appellate Division’s order.

Issue(s)

1. Whether the Appellate Division made the requisite factual findings to justify retaining Cruz in a non-secure mental health facility under Mental Hygiene Law § 33.15(b) and § 9.01, given conflicting expert opinions regarding his mental state.
2. Whether the definition of mental illness under Mental Hygiene Law § 1.03(20) excludes disorders for which an effective mode of treatment remains elusive.

Holding

1. Yes, the Appellate Division’s conclusion that Cruz should be transferred to a non-secure facility, based on the need for readjustment to life outside mental hospitals, constituted the requisite factual findings to justify retaining Cruz under Mental Hygiene Law § 33.15 (b) and § 9.01, because the evidence supported the finding that he continued to suffer from a severe mental disorder requiring in-patient care.
2. No, the definition of mental illness under Mental Hygiene Law § 1.03(20) does not exclude disorders solely because an effective mode of treatment has remained elusive, because the statute focuses on the presence of a disorder or disturbance requiring care, treatment, and rehabilitation.

Court’s Reasoning

The Court of Appeals reasoned that the evidence, including testimony from treating psychiatrists, the chief psychiatrist, and Cruz’s own expert, demonstrated that Cruz continued to suffer from a severe mental disorder. Even Cruz’s expert recommended retention in some level of custody. The court emphasized that Mental Hygiene Law § 1.03 (20) defines mental illness as an affliction manifested by a disorder in behavior, feeling, thinking, or judgment requiring care, treatment, and rehabilitation. The court stated, “It is enough that petitioner, as every psychiatric expert that testified at the hearing agreed, requires further in-patient care and attention.” The court found that the Appellate Division’s determination to transfer Cruz to a non-secure facility satisfied the requirement for factual findings justifying retention under Mental Hygiene Law § 33.15 (b) and § 9.01. The court rejected the argument that the Appellate Division avoided deciding whether Cruz remained in need of involuntary care and treatment, interpreting the Appellate Division’s reference to Cruz’s mental illness within the context of the pending retention application. The dissenting judge argued that the Appellate Division improperly deferred the determination of Cruz’s mental illness to the Commissioner, thus depriving Cruz of factual review and potentially violating his rights under Mental Hygiene Law § 33.15(b).