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Chavis v. State

United States District Court, D. New Jersey

March 12, 2018




         The plaintiffs, Sharon Chavis and her daughter Mya Chavis, seek injunctive relief and damages against the defendants, Jersey City Medical Center ("JCMC"), Meadowview Psychiatric Hospital ("Meadowview"), former Governor Chris Christie, and the State of New Jersey. After an altercation with some relatives, Sharon Chavis was admitted as a patient to JCMC, and shortly thereafter transferred to Meadowview. Plaintiffs allege that the defendants have violated several New Jersey and federal laws concerning the treatment of patients and disabled people. All of the defendants have moved to dismiss.[1] I have liberally construed the allegations of these pro se plaintiffs, but nevertheless I must grant the motions to dismiss.

         I. Summary[2]

         Sharon Chavis suffered a "minute and temporary" mental breakdown after an altercation with one of her daughters, Karen Chavis, and that daughter's boyfriend, Darryl Medina, over the treatment of the grandchildren. Sharon[3] was admitted to Jersey City Medical Center for physical and mental trauma. (Cplt. § 2; see also Pl. Opp. at 16.)[4] The complaint alleges that Karen retaliated against her mother by telling JCMC a fabricated story that Sharon was responsible for starting two fires. (Id.)

         Mya, Sharon's other daughter and plaintiff in this case, went to JCMC to visit her mother (Id. § 3.) On the morning of March 30, 2017, a nurse informed Mya that the hospital had released Sharon's information to Sharon's brother and could not release it to them. (Id.) Sharon has no brother. (Id.) Mya claims she was eventually able to figure out from a stranger at JCMC that her mother had been transferred to Meadowview the previous day, March 29, 2017. (Id.) At some point (die complaint is unclear as to when), a transfer from Meadowview to Kings Adult Care Center in Brooklyn, New York, was requested, but denied.[5]

         II. Discussion

         a. Standard of Review

         Fed. R. Civ. P. 12(b)(6) provides for the dismissal of a complaint, in whole or in part, if it fails to state claim upon which relief can be granted. The defendants, as the moving parties, each bear the burden of showing that no claim has been stated against them. Animal Science Products, Inc. v. China Minmetals Corp., 654 F.3d 462, 469 n.9 (3d Cir. 2011). For the purposes of a motion to dismiss, the facts alleged in the complaint are accepted as true and all reasonable inferences are drawn in favor of the plaintiff. N.J. Carpenters & the Trustees Thereof v. Tishman Const. Corp. of N.J., 760 F.3d 297, 302 (3d Cir. 2014).

         Moreover, when plaintiffs proceed pro se and without counsel, the complaint is to be "liberally construed, " and, "however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers." Erickson v. Pardus, 551 U.S. 89, 93-94 (2007). Nevertheless, “pro se litigants still must allege sufficient facts in their complaints to support a claim." Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013). "While a litigant's pro se status requires a court to construe the allegations in the complaint liberally, a litigant is not absolved from complying with Twombly and the federal pleading requirements merely because s/he proceeds pro se." Thakar v. Tan, 372 Fed.Appx. 325, 328 (3d Cir. 2010) (citation omitted).

         b. Request for Injunctive Relief

         Plaintiffs request injunctive relief repeatedly throughout the Complaint. However, they never explicitly state what form the injunctive relief should take or identify the persons against whom it should be ordered. This is of some concern because many of the alleged actions were not taken by or connected to some of the named defendants in the case (in particular, former Governor Chris Christie and the State of New Jersey).[6]

         The nearest the Complaint comes to requesting such relief is the request by plaintiffs that "[Sharon Chavis] be immediately removed from the jurisdiction of both hospitals[, ] Jersey City Medical Center [and] Meadowview Psychiatric Hospital[, ] as there is no legally substantiated reason why she is being held there." (Cplt. § 16.) She seeks this relief under the Civil Rights of Institutionalized Persons Act ("CRIPA"), 42 U.S.C. § 1997 et seq. I will interpret this as a request for injunctive relief against JCMC and Meadowview in the form of a court order mandating Sharon Chavis's release from either of those facilities.

         Article III of the United States Constitution limits the jurisdictional authority granted to district courts to those cases and controversies that are actual and ongoing. Borough of Avalon v. U.S. Army Corps of Eng'rs, No. 16-8057, 2017 WL 3917138, at *3 (D.N.J. Sept. 7, 2017) (citing Khodara Envtl, Inc. ex rel. Eagle Envtl, L.P. v. Beckman, 237 F.3d 186, 192-93 (3d Cir. 2001)). If the issues presented in a case are no longer "live, " the case is moot, and for an issue to be considered "live" there must be a real and substantial controversy between the parties that could be resolved through specific relief granted by the court. Id. (citing Old Bridge Owners Coop. Corp. v. Twp. of Old Bridge, 246 F.3d 310, 314 (3d Cir. 2001)). Putting aside whether the scheme under CRIPA is applicable in this case, I must first consider whether I have the authority to order the defendants to release Sharon.

         By the plaintiffs' own admission, even at the time of the filing of the complaint, Sharon had been transferred out of JCMC. Even when she was there, it appears that she was not under any restraints and was free to leave. (Cplt. § 2 ("The Plaintiff Sharon Chavis was seen and evaluated by Jersey City Medical Center Psychiatrist and Social Worker where she [was] verbally told that she was fit to be released by Jersey City Medical Center Medical Doctors. Plaintiff Sharon Chavis was then advised that she ...

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