United States Second Circuit

In a 42 U.S.C. section 1983 action based on plaintiff's involuntary commitment, denial of summary judgment for defendant is affirmed where: 1) the medical-standards test set forth in Rodriguez v. City of New York, 72 F.3d 1051 (2d Cir. 1995), for determining whether an involuntary commitment violates substantive due process, was not inconsistent with County of Sacramento v. Lewis, 523 U.S. 833 (1998); and 2) denying defendant-county summary judgment based on sovereign immunity did not require a showing that it acted with discriminatory animus or ill will toward plaintiff.

Appellate Information

• Argued 11/13/2009
• Decided 02/08/2010
• Published 02/08/2010

Judges

• McLAUGHLIN, Circuit Judge:, Before McLAUGHLIN and WESLEY, Circuit Judges, and KAHN, District Judge.

Court

• United States Second Circuit

Counsel

• For Appellees:
  
• Emily V. Melendez, Assistant Attorney General, for Richard Blumenthal, Attorney General of the State of Connecticut, Office of the Attorney General, Hartford, CT, for Defendants-Appellants., William Brooks, Touro Law Center, Central Islip, NY, for Plaintiff-Appellee., Nancy B. Alisberg, Office of Protection & Advocacy for Persons with Disabilities, Hartford, CT, for Plaintiff-Appellee., Susan J. Kohlmann, Jenner & Block LLP (Danielle F. Tarantolo, on the brief), New York, NY, for Amici Curiae National Disability Rights Network, New York Lawyers for the Public Interest, and Vermont Protection & Advocacy, Inc., in support of Plaintiff-Appellee.