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New York Discharge-Planning: The Term “City Jail” Includes Mental Health “Forensic Units”
New York Discharge-Planning: The Term "City Jail" Includes Mental Health "Forensic Units"
A unanimous Appellate Division of the New York Supreme Court held that a class action settlement agreement obliging discharge-planning for "city jail" prisoners necessarily included those prisoners who were isolated in "secure hospital units" or "prison wards" while receiving treatment for mental illnesses.
The City of New York had tried to weasel out of providing discharge-planning for mentally ill prisoners by construing the settlement-agreement term "city jail" to restrict applicability solely to those prisoners who were in mainline lockup units. The Supreme Court below had rejected the City's argument that the term "city jail" was ambiguous.
The Appellate Division construed New York City Charter § 623(1), which invests the Correction Commissioner with the "charge and management of all institutions in the city, including all hospital wards therein for the care and custody of [prisoners] ... including those requiring psychiatric ... treatment, except such places for the detention of prisoners as are placed by law under the charge of some other agency."
The class settlement agreement referred to "city jail" as "a correctional facility operated by [the] Department of Correction." The court interpreted the latter narrower definition as not reasonably excluding prisoners removed to secure mental health wards. Although the settlement agreement did not expressly mention "forensic units," the court observed that "ambiguity does not arise from silence, but from what [is] written so blindly and imperfectly that its meaning is doubtful." The agreement's narrower use of the term "mental health centers" here could therefore not arguably lead to a conclusion that these centers were intended to be excluded from the term "city jails."
Accordingly, the Appellate Division affirmed the Supreme Court. See: Brad H. v. City of New York, 33 A.D.3d 301, 822 N.Y.S.2d 245 (N.Y.A.D. 1 Dept. 2006).
A unanimous Appellate Division of the New York Supreme Court held that a class action settlement agreement obliging discharge-planning for "city jail" prisoners necessarily included those prisoners who were isolated in "secure hospital units" or "prison wards" while receiving treatment for mental illnesses.
The City of New York had tried to weasel out of providing discharge-planning for mentally ill prisoners by construing the settlement-agreement term "city jail" to restrict applicability solely to those prisoners who were in mainline lockup units. The Supreme Court below had rejected the City's argument that the term "city jail" was ambiguous.
The Appellate Division construed New York City Charter § 623(1), which invests the Correction Commissioner with the "charge and management of all institutions in the city, including all hospital wards therein for the care and custody of [prisoners] ... including those requiring psychiatric ... treatment, except such places for the detention of prisoners as are placed by law under the charge of some other agency."
The class settlement agreement referred to "city jail" as "a correctional facility operated by [the] Department of Correction." The court interpreted the latter narrower definition as not reasonably excluding prisoners removed to secure mental health wards. Although the settlement agreement did not expressly mention "forensic units," the court observed that "ambiguity does not arise from silence, but from what [is] written so blindly and imperfectly that its meaning is doubtful." The agreement's narrower use of the term "mental health centers" here could therefore not arguably lead to a conclusion that these centers were intended to be excluded from the term "city jails."
Accordingly, the Appellate Division affirmed the Supreme Court. See: Brad H. v. City of New York, 33 A.D.3d 301, 822 N.Y.S.2d 245 (N.Y.A.D. 1 Dept. 2006).
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Related legal case
Brad H. v. City of New York
| Year | 2006 |
|---|---|
| Cite | 33 A.D.3d 301, 822 N.Y.S.2d 245 (N.Y.A.D. 1 Dept. 2006) |
| Level | State Court of Appeals |
| Injunction Status | N/A |