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The Importance of Procedural Due Process: A Successful Expungement of a Mental Health Commitment In Erie County, PA

J. Chadwick Schnee, Esq • January 1, 2025

The Importance of Procedural Due Process: A Successful Expungement of a Mental Health Commitment in Erie County, PA

In the realm of mental health law, the rights of individuals to due process are paramount, ensuring that any involuntary commitment is conducted with the utmost respect for legal procedures. Recently, at Schnee Legal Services, LLC, we achieved a significant legal victory in Erie County, Pennsylvania, which underscores the critical nature of procedural due process under the Pennsylvania Mental Health Procedures Act.


The Case at Hand


The case involved an individual who was involuntarily committed under Section 302 of the Mental Health Procedures Act. This section allows for emergency involuntary examination and treatment for up to 120 hours if a person is deemed to be severely mentally disabled and in need of immediate treatment. However, the Act also mandates specific procedural safeguards to protect the rights of the individual, including the requirement that a person must be examined by a physician within two hours of arriving at a mental health facility.


In this instance, the commitment paperwork did not clearly demonstrate that this critical examination had taken place within the required timeframe. This lack of documentation was a clear violation of procedural due process, which is designed to ensure that individuals are not unjustly deprived of their liberty.


Legal Argument and Outcome


Our argument centered on the insufficiency of evidence regarding the timely examination. We contended that without clear proof of adherence to this procedural step, the commitment could not stand as legally valid. Here's how we approached this:



  • Evidence Review: We meticulously reviewed all available records from the hospital. The documentation lacked clear timestamps or notes indicating that an examination had occurred within the two-hour window post-arrival.
  • Legal Precedent: We cited relevant case law that emphasized the court's role in reviewing the sufficiency of evidence used in commitments. We argued that case law supported our need for clear documentation to uphold the commitment legally.
  • Due Process Violation: We highlighted that the absence of such documentation was not just an administrative oversight but a significant breach of the individual’s due process rights, potentially leading to wrongful deprivation of liberty.


The court agreed with our arguments. Recognizing the procedural due process violation, the court ordered the expungement of the involuntary commitment from the individual's record. This decision was not only a win for our client but also a reaffirmation of the legal system's commitment to protecting individual rights against potential abuses under the guise of mental health treatment.


Implications


This case serves as a reminder of the delicate balance between public safety and individual rights. It underscores the importance of:


  • Documentation: Every step in the commitment process must be meticulously documented to withstand legal scrutiny.
  • Timeliness: The requirement for a timely medical examination is not merely procedural; it is a safeguard against wrongful commitments.
  • Legal Representation: Having competent legal representation can make the difference between a record that haunts an individual for life and one that is rightfully expunged.


Conclusion


At Schnee Legal Services, LLC, we remain committed to defending the rights of individuals in mental health law matters. This case in Erie County is a testament to our dedication to ensuring that every procedural aspect of the law is adhered to, protecting our clients from potential injustices. If you or someone you know has been subjected to an involuntary commitment and believe there may have been procedural irregularities, please contact us at chadwick@schneelegal.com or visit our website at www.schneelegal.com. We're here to help you navigate the complexities of the legal system and seek justice.


Note: This post does not constitute legal advice. For legal advice specific to your situation, please consult with an attorney.

Legal Insights with Attorney Schnee, Navigating the Path of Justice

A large library filled with lots of books on shelves.

Are public libraries subject to the Right-to-Know Law? Definitely maybe.

By J. Chadwick Schnee, Esq • December 1, 2024
Are public libraries subject to the Right-to-Know Law? Definitely maybe.
A scale of justice sits on a wooden podium in a courtroom

Post-trial motions not required in Right-to-Know Law enforcement

By J. Chadwick Schnee, Esq • November 1, 2024
As a matter of first impression, a Commonwealth Court judge has ruled that post-trial motions under Pa. R.Civ.P. 227.1 are not required in an appeal from an order in a Right-to-Know Law enforcement action. In Walker v. County of Bucks, a requester filed an enforcement action against an agency and its open-records officer where the agency had filed two appeals of the same OOR final order (rather than two appeals of two different OOR final orders), arguing that relief in mandamus was appropriate because one of the two OOR final orders was not appealed.[1] The trial court rejected the complaint, holding that relief in mandamus “is not clear at this time” due to a pending motion to substitute one its appeals.[2] The requester appealed but did not file post-trial motions. The agency argued that, under Pa.R.Civ.P. 227.1, the requester “waived all issues on appeal and her appeal must be dismissed” because she did not file post-trial motions. Commonwealth Court Judge Dumas disagreed, holding that a RTKL enforcement action “is not a situation where post-trial motions had to be filed” because the complaint in mandamus was covered by “‘petition practice’” as set forth under the Note to Pa R.A.P. 3761.[3] Instead, “it is evident that the mandamus action filed by Appellant was in petition practice, such that post-trial motions were not necessary.”[4] While this is an unreported memorandum opinion of a single member of the Commonwealth Court, parties to a RTKL enforcement action potentially may not be required to file post-trial motions in order to preserve issues on appeal. (This post should not be considered legal advice. For more information or to discuss, Attorney Schnee can be reached at chadwick@schneelegal.com ). [1] Walker v. County of Bucks, 974 C.D. 2023 (Pa.Cmwlth. Jan. 31, 2024) (Dumas, J.) (unreported). The author represents the requester in this matter. [2] Id. [3]The Note provides Pa.R.A.P. 3761(b) provides the method for seeking compliance with a final determination of the Office of Open Records in the Commonwealth Court. This differs from proceeding in the courts of common pleas, where the method to obtain judicial review of alleged failure to comply with a final determination of the Office of Open Records may be an action in mandamus or other petition authorized by local rule. Capinski v. Upper Pottsgrove Township, 164 A.3d 601 (Pa. Cmwlth. 2017). Use of this petition is appropriate when the final determination was not appealed. If an appeal was taken and the order affirmed by the Commonwealth Court, enforcement is not of the final determination of the Office of Open Records, but rather of the order of the Commonwealth Court. [4] Walker v. County of Bucks, 974 C.D. 2023 (Pa.Cmwlth. Jan. 31, 2024) (Dumas, J.) (unreported).
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