State ex rel. Riley v. Rudloff

Summary

The West Virginia Supreme Court of Appeals considered whether West Virginia Code § 27-5-2(a), which barred applications for involuntary hospitalization of incarcerated persons, violated a pretrial detainee’s due process right to necessary medical care. The court applied the reasonable-relationship test for conditions of pretrial confinement and concluded that the categorical exclusion of pretrial detainees from the involuntary-hospitalization application process was not rationally related to a legitimate governmental objective. The court granted relief in prohibition as moulded.

Holdings

1. West Virginia Code § 27-5-2(a) is unconstitutional insofar as its reference to incarcerated persons wholly excludes pretrial detainees in state custody from participating in the application process for involuntary hospitalization, because the exclusion violates their due process right to receive medical care.
2. A writ of prohibition is appropriate, as moulded, to prohibit the Commissioner from rejecting involuntary-hospitalization applications submitted on behalf of pretrial detainees solely because the detainees are incarcerated.
3. The plain language of West Virginia Code § 27-5-2(a) expressly excludes incarcerated persons from the application process, and the court must apply that language as written before determining its constitutionality.

Questions Presented

1. Whether West Virginia Code § 27-5-2(a), insofar as it categorically excluded pretrial detainees from the application process for involuntary hospitalization, violated the due process protections of the Fourteenth Amendment and Article III, Section 10 of the West Virginia Constitution.
2. Whether a writ of prohibition was an appropriate remedy against the Commissioner's refusal to accept involuntary-hospitalization applications submitted on behalf of pretrial detainees.
3. Whether the statutory exclusion bore a reasonable relationship to a legitimate, nonpunitive governmental objective under the due process standard governing conditions of pretrial confinement.

Disposition

writ_granted