The Second Circuit Court of Appeals has delivered a significant ruling, overturning a lower court’s decision and establishing that residents voluntarily admitted to state developmental disability facilities retain substantive due process rights to adequate medical care. The ruling mandates that the case be sent back to the District Court for further action, potentially reviving the federal constitutional claims brought by the mother of a deceased resident.
The case centers on the tragic death of C.B., who resided at the Valley Ridge Center for Intensive Treatment, a facility operated by the New York State Office for People with Developmental Disabilities (OPWDD). C.B.’s mother, J.M., alleged that the caretakers at Valley Ridge ignored C.B.’s obvious signs of heart failure, leading to his death. She sued under 42 U.S.C. § 1983 for violating C.B.’s substantive due process rights, alongside state law claims for negligence and medical malpractice.
The District Court for the Northern District of New York had previously dismissed the federal claim, concluding that because C.B. had *voluntarily* admitted himself to the facility, the state did not incur the affirmative constitutional duty to provide adequate medical care required under the Due Process Clause. The Second Circuit panel disagreed, finding this distinction irrelevant in the context of custodial care.
The Crux of the Ruling: State Control Over Admission Status
The core of the appellate decision hinged on reconciling two key precedents: *Youngberg v. Romeo* (which established a right to adequate care for involuntarily committed patients) and *DeShaney v. Winnebago County Department of Social Services* (which generally limits the state’s affirmative duty to protect citizens from harm).
The Defendants argued that *DeShaney* effectively overruled prior Second Circuit precedent, *Society for Good Will to Retarded Children, Inc. v. Cuomo*, which held that the distinction between voluntary and involuntary admission was “irrelevant” once an individual was institutionalized.
However, the Second Circuit panel, writing through Judge Maria Araújo Kahn, firmly rejected this argument. The court emphasized that *DeShaney* concerned a child harmed by private actors (his father) while remaining in the community. In contrast, cases like *Youngberg* and *Society for Good Will* involve situations where “the State by the affirmative exercise of its power so restrains an individual’s liberty that it renders him unable to care for himself.”
The court found that C.B.’s voluntary status did not negate the state’s constitutional obligations because the actual level of control exerted by Valley Ridge was virtually identical to that imposed on involuntarily committed residents.
“Admission status is a poor measure of the state’s control and the resident’s resulting dependence,” the opinion stated. At Valley Ridge, all residents faced the same restrictions: they were not free to leave at will, required staff supervision, and needed director permission to exit. Furthermore, staff were reportedly not even informed about which residents were voluntary versus involuntary.
The court noted that a voluntary resident seeking to leave must submit a written request, which the director can legally hold for up to 72 hours if they believe involuntary care might be necessary. This process, the court reasoned, means a resident is “free to ask to leave but not actually free to leave.”
By “exercising sufficient control over a voluntarily committed resident’s life” to the point where they are “incapable of helping themselves,” the state triggers the protections of the Due Process Clause, irrespective of initial admission paperwork.
C.B.’s Final Days and Medical Neglect
The factual background detailed in the opinion paints a grim picture of alleged neglect in C.B.’s final days. Diagnosed with hypertension, C.B. experienced rapid weight gain and complained of severe symptoms, including difficulty breathing, chest pain, and lethargy—all known signs of heart failure.
On April 4, 2018, staff member Katherina Cassata observed C.B. looking “physically sick,” sweating, clammy, and breathless. She notified a nurse who allegedly told him only to “have some water” and “go lay down.” The next day, after C.B. told his mother and supervisor Michael Novack he couldn’t breathe and needed a hospital, he was seen by Nurse Elise Williams. Williams reportedly failed to check crucial vital signs like his respiratory rate or perform an EKG, attributing his symptoms to sinus congestion and advising him to hydrate—advice the plaintiff’s expert claimed was actively dangerous for someone with cardiomyopathy.
The night of his death, trainee staff member Ashley Sessions allegedly falsified records, skipping two required 2:00 AM bed checks to watch movies, a failure her supervisor, Corey Behlen, overlooked. C.B. died alone sometime between 4:00 AM and 6:00 AM, likely experiencing the sensation of drowning due to pulmonary edema.
Qualified Immunity and Next Steps
The Defendants had also argued for qualified immunity, claiming the right for a voluntarily admitted resident to adequate care was not “clearly established.” The Second Circuit rejected this as well, citing decades of precedent from *Youngberg* onward confirming the right to medical care for dependent residents in state custody. Because staff were reportedly unaware of voluntary/involuntary status anyway, they could not reasonably rely on C.B.’s status to justify their actions.
However, the court stopped short of ruling on the specific conduct of each Defendant, stating it is the district court’s role to examine the factual disputes regarding individual liability in the first instance.
The ruling vacates the District Court’s summary judgment order and remands the case for further proceedings consistent with the opinion. This means the § 1983 claim is back on the table, and the District Court will need to address the qualified immunity defense for each caretaker and potentially proceed toward trial on the merits of the constitutional violation and the state law claims.