Summary
This Connecticut Appellate Court opinion addresses an appeal by a plaintiff involuntarily civilly committed to a state psychiatric hospital who sought declaratory and injunctive relief regarding periodic review requirements and discharge procedures. The appellate court reversed the trial court's grant of summary judgment for the defendants, holding that the plaintiff lacked individual standing to assert her claims for declaratory and injunctive relief. Consequently, the court also found she lacked typicality for class certification and remanded the case with directions to dismiss the action.
Topics
Practice areas
Questions Presented
- Whether the plaintiff had standing to seek declaratory and injunctive relief challenging Connecticut's statutory periodic-review process and the availability of less restrictive placements for involuntarily committed psychiatric patients.
- Whether the plaintiff had standing to challenge the timeliness of probate review hearings.
- Whether the plaintiff had the requisite typicality to represent a class under Practice Book § 9-7 when she lacked individual standing.
Holdings
- The plaintiff lacked standing because she did not demonstrate a specific, personal, and legal interest that had been specially and injuriously affected. The Probate Court had found that she continued to meet the statutory standard for civil commitment, and she had received prompt review hearings and a timely discharge once an appropriate placement became available.
- The plaintiff lacked standing to challenge the timeliness of probate review hearings because she received prompt attention and docketing of matters relating to her continued commitment, including an annual hearing only two months after she was designated discharge ready.
- Because the plaintiff lacked individual standing, she also lacked the requisite typicality to raise the same claims on behalf of a class under Practice Book § 9-7.
Key quotations
“Standing is established by showing that the party claiming it is authorized by statute to bring suit or is classically aggrieved.”
“Without individual standing to raise a legal claim, a named representative does not have the requisite typicality to raise the same claim on behalf of a class.”
Factual background
Drummer was involuntarily civilly committed to Connecticut Valley Hospital on October 14, 2016. Her treatment team deemed her discharge ready on August 2, 2017, but the Middletown Probate Court later found that she continued to have psychiatric disabilities and was gravely disabled, and that no less restrictive placement was then available. After the plaintiff brought suit, she was released to Lotus Home in March 2018 and later moved to state-funded senior housing.
Procedural history
Drummer was involuntarily committed to Connecticut Valley Hospital in 2016 and was designated discharge ready in 2017. The Middletown Probate Court conducted review hearings, found that she continued to meet the statutory standard for civil commitment, and later released her to a residential facility. In the Superior Court, the plaintiff's motions for class certification were denied, and the court ultimately denied her summary-judgment motion and granted summary judgment for the defendants. The Appellate Court concluded that the plaintiff lacked standing and remanded for dismissal.
Remand instructions
Reverse the trial court's judgment only as to the form of the judgment and remand with direction to render a judgment dismissing the action.