Massachusetts General Hospital v. C.R.

Summary

The Supreme Judicial Court of Massachusetts held that the three-day involuntary hospitalization period under G. L. c. 123, § 12 (b), begins when a patient is admitted to an authorized psychiatric facility, not when the patient is initially restrained or held in an emergency department under § 12 (a). The court also concluded that the record did not establish a due process violation arising from the patient's confinement and declined to decide broader constitutional challenges to emergency-department boarding.

Holdings

1. The restraint, preliminary evaluation, and application process under G. L. c. 123, § 12(a), is distinct from the three-day involuntary hospitalization and evaluation period under § 12(b). The § 12(b) period begins when the patient is admitted to an authorized psychiatric facility, not when the patient is initially brought to an emergency department under § 12(a).
2. As applied to C.R., the § 12(a) confinement did not violate due process because the restraint lasted no longer than necessary to locate an appropriate facility, the placement process was complicated by her need for a private room, and no less restrictive suitable location was identified.
3. The court declined to decide broader constitutional questions concerning the facial validity of § 12(a) or emergency-department boarding generally because those questions were premature in this individual appeal, which was not a class action, declaratory judgment action, or facial challenge.

Questions Presented

1. Whether the three-day involuntary hospitalization period under G. L. c. 123, § 12(b), begins when a patient is initially restrained or brought to an emergency department under § 12(a), or only when the patient is admitted to an authorized psychiatric facility under § 12(b).
2. Whether the statutory scheme violated C.R.'s due process rights as applied to her five-day emergency-department confinement while an appropriate psychiatric placement was located.
3. Whether the Supreme Judicial Court should decide broader facial or general constitutional challenges to the length of § 12(a) restraint and emergency-department boarding.

Disposition

reversed