Justia Health Law Opinion SummariesArticles Posted in Maine Supreme Judicial Court
A.S. v. LincolnHealth
The Supreme Judicial Court vacated the judgment of the superior court denying A.S.'s petition for a writ of habeas corpus seeking release from his detention, holding that the superior court erred when it determined that the detention was lawful.A.S. was brought by law enforcement officers to the LincolnHealth Miles Hospital Campus and was held in the hospital's emergency department for thirty days. During that time, LincolnHealth did not seek or obtain judicial endorsement of its detention of A.S., as required by Me. Rev. Stat. 34-B, 3863. A.S. sought habeas corpus relief, arguing that LincolnHealth violated the statutory procedure for emergency involuntary hospitalization. The superior court denied the petition. The Supreme Court vacated the superior court's judgment, holding (1) A.S.'s detention was unauthorized because the hospital did not comply with section 3863; and (2) A.S.'s due process rights were violated when the superior court applied a standard of preponderance of the evidence, rather than clear and convincing evidence, to determine whether A.S. posed a likelihood of serious harm at the time of the habeas hearing. View "A.S. v. LincolnHealth" on Justia Law
In re Involuntary Commitment of M.
The Supreme Judicial Court affirmed the order of the district court committing M. to involuntary hospitalization for up to 120 days, holding that the evidence was sufficient to support the court's decision to order M.'s involuntary hospitalization.The district court authorized M.'s hospitalization for up to 120 days, and the superior court affirmed. On appeal, M. argued that she was denied due process and a fair appeal because there was no verbatim transcript of her commitment hearing and that the record contained insufficient evidence to support the court's findings. The Supreme Judicial Court affirmed, holding (1) the opportunities afforded to M. to supplement the incomplete transcript were sufficient to satisfy due process; and (2) there was sufficient evidence to support the district court's decision. View "In re Involuntary Commitment of M." on Justia Law
In re Involuntary Treatment of K.
The Supreme Judicial Court dismissed as moot Appellant's appeal from a judgment entered by the superior court ordering the involuntary medical treatment of Appellant, holding that because Appellant was no longer subject to the court's involuntary treatment order, this appeal was moot.Appellant was arrested and charged with burglary and theft by unauthorized taking. While Appellant was in preconviction detention at the mental health unit of the Maine State Prison (MSP) the Department of Corrections filed an application pursuant to Me. Rev. Stat. 34-A, 3049 seeking the involuntary medication of Appellant. The court entered an ex parte order granting the emergency application and permitting the immediate medication of Appellant for a period of 120 days. Appellant appealed. The Supreme Judicial Court dismissed the appeal as moot, holding that because Appellant was no longer at the mental health unit of the MSP and the involuntary treatment order had expired, the appeal was moot and no exceptions to the mootness doctrine applied. View "In re Involuntary Treatment of K." on Justia Law
AngleZ Behavioral Health Services v. Department of Health and Human Services
The Supreme Judicial Court vacated the judgment of the superior court vacating a Department of Health and Human Services hearing officer's decision requiring AngleZ Behavioral Health Services to pay $392,603.31 in MaineCare reimbursements because of billing errors, holding that the superior court erred by finding that the Department did not submit proper evidence in support of some of its recoupment claims.After auditing the claims submitted by AngleZ between February 13, 2013 and July 20, 2013 The Department issued a notice of violation applying an error rate to all of AngleZ's claims during that time period. The Department ultimately sought a total recoupment of $392,603.31. A hearing officer concluded that the Department was correct in seeking 392,603.31 in recoupment, and the Department's acting commissioner adopted the recommendation. The superior court vacated the Commissioner's decision, concluding that the hearing officer's decision was not supported by substantial evidence. The Supreme Judicial Court vacated the superior court's judgment, holding that the hearing officer's decision was supported by substantial evidence and was neither arbitrary nor capricious. View "AngleZ Behavioral Health Services v. Department of Health and Human Services" on Justia Law
In re Adult Guardianship of L.
The Supreme Judicial Court vacated the judgment of the probate court denying L.'s petition for termination of his adult guardianship, holding that the court applied an incorrect standard of proof in contravention of Me. Rev. Stat. 18-A, 5-307(d).In denying L.'s petition the probate court determined that L. "failed to prove by clear and convincing evidence that his adult guardianship was no longer necessary for his safety and well-being." The Supreme Court vacated the judgment, holding (1) Me. Rev. Stat. 18-A, 5-307(d) sets forth the burden of proof applicable to L.'s petition for termination of guardianship; and (2) the probate court in this case failed to apply the proper statutory standard of proof in denying L.'s petition. View "In re Adult Guardianship of L." on Justia Law
In re Patricia S.
The Supreme Judicial Court vacated the judgment of the probate court denying the petition filed by Michael Zani and Peter Zani to be appointed co-guardians of Patricia S., their mother and an incapacitated adult, and instead appointing Karin Beaster and Nancy Carter as co-guardians, holding that Beaster and Carter had not fulfilled the pretrial filing requirements of Me. Rev. Stat. 18-A, 5-303(a).The probate court appointed Beaster and Carter as co-guardians of Patricia even though Beaster and Carter had not filed petitions to be appointed. The Supreme Judicial Court vacated the judgment, holding that the superior court erred by appointing Beaster and Carter when they had not complied with the requirements applicable to a guardianship petition under section 5-303(a). View "In re Patricia S." on Justia Law
Guardianship of David P.
The Supreme Judicial Court affirmed the judgment of the probate court appointing the Department of Health and Human Services as David P.’s limited public guardian pursuant to Me. Rev. Stat. 18-A, 5-601, holding that any error on the part of the probate court was harmless and that there was sufficient competent evidence in the record to support the probate court’s judgment.On appeal, David argued that there was insufficient evidence to support the probate court’s decision and that the court erred in admitting a written report drafted by a psychologist in violation of the rule against hearsay. The Supreme Judicial Court held (1) it was error for the probate court to admit the psychologist’s written report in its entirety, but the error was harmless; and (2) the evidence was sufficient to support the judgment. View "Guardianship of David P." on Justia Law
Argereow v. Weisberg
After correcting one aspect of the judgment, the Supreme Judicial Court affirmed the judgment of the superior court granting Defendants’ motions to dismiss Plaintiff’s complaint stemming from a hospital’s decision not to employ her, holding that the superior court correctly granted the hospital's and a physician's separate motions to dismiss the complaint for failure to state claims upon which relief could be granted because some counts failed due to the absolute immunity provisions of the Maine Health Security Act, Me. Rev. Stat. 24, 2501-2988, and other counts were legally insufficient.Plaintiff filed a second amended complaint against a physician and a hospital, asserting various claims. The superior court dismissed the counts against the physician, determining he was entitled to immunity pursuant to Me. Rev. Stat. 24, 2511, and dismissed the claims against the hospital for failure to state claims upon which relief could be granted. On appeal, the Supreme Judicial Court held that the superior court correctly dismissed all claims against the physician because he was immune from civil liability, but the judgment dismissing the claims against the physician for defamation, slander per se, and negligent infliction of emotional distress was corrected as dismissals with prejudice. View "Argereow v. Weisberg" on Justia Law
Oliver v. Eastern Maine Medical Center
In this professional negligence action, the Supreme Judicial Court affirmed the judgment of the superior court concluding that Defendant, a medical center, was not negligent when it discharged Plaintiffs’ father, who died the night he was discharged.After a bench trial, the superior court concluded that Defendant was not negligent when it discharged the decedent over the objection of his guardians and that the discharge plan met the standard of care. The Supreme Judicial Court affirmed, holding that the superior court (1) did not err in concluding that, at the time he was discharged, Defendant had regained capacity to make his own health-care decisions and that Defendant’s discharge plan met the standard of care; and (2) did not err in denying Defendant’s request for costs for expert witness fees and expenses incurred during the prelitigation screening panel process. View "Oliver v. Eastern Maine Medical Center" on Justia Law
Begin v. State
The Supreme Judicial Court affirmed the judgment of the superior court denying Appellant’s petition for release and discharge from the custody of the Commissioner of Health and Human Services pursuant to Me. Rev. Stat. 15, 104-A. The Court held that, contrary to Appellant’s argument on appeal, the superior court applied the correct standard when it denied Appellant’s petition for release and discharge and properly denied the petition where Appellant failed to prove that he “may be released or discharged without likelihood that [he] will cause injury to [himself] or to others due to a mental disease or mental defect.” View "Begin v. State" on Justia Law