Mamonet v. T.L.R. Bronx Psychiatric Center

Background

Dwayne Mamonet, proceeding without a lawyer, filed a federal-question action under 28 U.S.C. § 1331. He sought money damages for an alleged violation of his constitutional rights arising from his involuntary hospitalization. He named “T.L.R./Bronx Psychiatric Center, Parker Building State. Bronx, State,” which the court understood to be the Bronx Psychiatric Center, operated by the New York State Office of Mental Health.

Mamonet alleged that he had been held against his will at “Bronx State” during an involuntary hospitalization. He also alleged that Betty Parker Bronx State sent him to an Office of Mental Health building on Tremont Avenue called Hughes Apt., where he was then housed. He stated that he had been sick and homeless for years while at the institutions. The opinion does not specify the relevant dates of the hospitalization or identify individual defendants.

Screening standard

Because Mamonet had been allowed to proceed without prepaying filing fees, the court was required to review his complaint. Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss a complaint that is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant immune from that relief. The court must also dismiss a case when it lacks subject-matter jurisdiction. The court stated that it would read a self-represented plaintiff’s allegations liberally, but the complaint still had to provide enough facts to make a legally plausible claim.

Eleventh Amendment immunity

The court held that the Bronx Psychiatric Center was effectively an arm of New York State. The court stated that New York had not waived its Eleventh Amendment immunity from federal lawsuits and that Congress had not removed that immunity when it enacted 42 U.S.C. § 1983. The court therefore dismissed all claims against “T.L.R./Bronx Psychiatric Center, Parker Building State. Bronx, State” under the Eleventh Amendment.

Section 1983 and personal involvement

The court interpreted Mamonet’s allegations as asserting a claim under 42 U.S.C. § 1983 based on the Fourteenth Amendment’s due process protection. To proceed under Section 1983, a plaintiff must allege that a federal right was violated by a person acting under state authority. The plaintiff must also allege facts showing each defendant’s direct and personal involvement. A defendant cannot be held liable merely because that defendant employs or supervises someone who allegedly violated the plaintiff’s rights.

Mamonet did not name any individual defendants or suggest that any particular individual was personally involved in the alleged constitutional violations. The court therefore granted him permission to amend so that he could identify and describe the conduct of the individuals he claimed violated his rights.

Involuntary hospitalization

The court explained that involuntary hospitalization seriously restricts a person’s liberty and therefore requires due process. It stated that New York generally must show that a person presents a danger to himself or others and must follow procedures governing involuntary commitment, including procedures allowing the person to challenge the commitment in court. The court noted that the Second Circuit had held the relevant provisions of New York’s Mental Hygiene Law facially constitutional.

The court found that Mamonet had not alleged facts showing that a state actor violated his due process rights during his commitment. His objection to being involuntarily committed, without more, was insufficient to state a claim. The court granted him leave to provide additional facts supporting that claim.

Leave to amend and disposition

The court granted Mamonet 60 days to file an amended complaint. It directed him to provide a short statement of the facts supporting each claim against each defendant, including relevant names and titles, what each defendant did or failed to do, approximate dates and locations, his injuries, and the relief requested. The amended complaint would replace the original complaint rather than supplement it, so any facts or claims he wanted to preserve had to be repeated.

The court directed the Clerk to mail the order to Mamonet and stated that no summons would issue at that time. It warned that if Mamonet did not timely amend and could not show good cause for the failure, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.