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Settlement in New York City Jail Mental Health Services Case Still Alive
On June 28, 2011, the New York Court of Appeals held that a motion to extend the obligations of New York City officials to provide mental health services to jail prisoners was timely because it was filed before the settlement agreement in the case expired.
A group of mentally ill prisoners in New York City jails brought suit in 1999, alleging that “the City had failed to satisfy its duty under the State Constitution and Mental Hygiene Law to provide adequate ‘discharge planning’ services for mentally ill persons completing their terms of incarceration.”
The Supreme Court for New York County certified the case as a class action and granted preliminary injunctive relief. [See: PLN, Jan. 2002, p.14]. The parties then entered into a settlement agreement, which was approved by the court on April 4, 2003.
Two compliance monitors were appointed on May 6, 2003 to oversee the City’s efforts, and the settlement was im-plemented on June 3, 2003.
“The monitors ... did not begin their work monitoring the City’s activities ‘in earnest’ until June 25, 2003 and, even as of the filing of the September 2003 report, they were unable to provide an opinion regarding the City’s compliance with the agreement,” according to the Court of Appeals.
The settlement included a termination clause providing for expiration “at the end of five years after monitoring by the Compliance Monitors” began. The parties subsequently consented to extensions that tolled the termination date by 356 days. Thus, the expiration date was to be calculated using five years plus 356 days.
The settlement agreement also allowed the plaintiffs to “ask the Supreme Court to extend the settlement for an additional two-year period” if they “could demonstrate before the agreement expired that the City had failed to adequately discharge its responsibilities for two years.”
On May 22, 2009, the plaintiffs moved to enforce the settlement. The defendants moved to dismiss, arguing that the motion was untimely and the court lacked jurisdiction because the settlement agreement had expired in April 2009.
The Supreme Court denied the defendants’ motion, “concluding that the five-year term began on the implementation date and that the expiration date occurred on May 25 or 26, 2009, thereby rendering plaintiffs’ motion timely.”
The Appellate Division reversed, however, “holding that the five-year term commenced when the monitors engaged in their first affirmative act on either May 19th or 28th in 2003, which produced a termination date of either May 10th or 19th in 2009, both of which were prior to the filing date of plaintiffs’ motion.”
Applying “traditional principles of contract interpretation,” the Court of Appeals reversed the Appellate Division, finding that the monitoring of the City’s compliance obligations did not begin until June 3, 2003. Hence, “the agreement did not terminate until at least five years and 356 days later on May 25 or 26, 2009. Since plaintiffs filed their motion ... on May 22, 2009, [the] Supreme Court did not lack jurisdiction over the case and it properly denied the City’s ... motion to dismiss.” See: Brad H. v. The City of New York, 17 N.Y.3d 180, 951 N.E.2d 743 (N.Y. 2011).
A group of mentally ill prisoners in New York City jails brought suit in 1999, alleging that “the City had failed to satisfy its duty under the State Constitution and Mental Hygiene Law to provide adequate ‘discharge planning’ services for mentally ill persons completing their terms of incarceration.”
The Supreme Court for New York County certified the case as a class action and granted preliminary injunctive relief. [See: PLN, Jan. 2002, p.14]. The parties then entered into a settlement agreement, which was approved by the court on April 4, 2003.
Two compliance monitors were appointed on May 6, 2003 to oversee the City’s efforts, and the settlement was im-plemented on June 3, 2003.
“The monitors ... did not begin their work monitoring the City’s activities ‘in earnest’ until June 25, 2003 and, even as of the filing of the September 2003 report, they were unable to provide an opinion regarding the City’s compliance with the agreement,” according to the Court of Appeals.
The settlement included a termination clause providing for expiration “at the end of five years after monitoring by the Compliance Monitors” began. The parties subsequently consented to extensions that tolled the termination date by 356 days. Thus, the expiration date was to be calculated using five years plus 356 days.
The settlement agreement also allowed the plaintiffs to “ask the Supreme Court to extend the settlement for an additional two-year period” if they “could demonstrate before the agreement expired that the City had failed to adequately discharge its responsibilities for two years.”
On May 22, 2009, the plaintiffs moved to enforce the settlement. The defendants moved to dismiss, arguing that the motion was untimely and the court lacked jurisdiction because the settlement agreement had expired in April 2009.
The Supreme Court denied the defendants’ motion, “concluding that the five-year term began on the implementation date and that the expiration date occurred on May 25 or 26, 2009, thereby rendering plaintiffs’ motion timely.”
The Appellate Division reversed, however, “holding that the five-year term commenced when the monitors engaged in their first affirmative act on either May 19th or 28th in 2003, which produced a termination date of either May 10th or 19th in 2009, both of which were prior to the filing date of plaintiffs’ motion.”
Applying “traditional principles of contract interpretation,” the Court of Appeals reversed the Appellate Division, finding that the monitoring of the City’s compliance obligations did not begin until June 3, 2003. Hence, “the agreement did not terminate until at least five years and 356 days later on May 25 or 26, 2009. Since plaintiffs filed their motion ... on May 22, 2009, [the] Supreme Court did not lack jurisdiction over the case and it properly denied the City’s ... motion to dismiss.” See: Brad H. v. The City of New York, 17 N.Y.3d 180, 951 N.E.2d 743 (N.Y. 2011).
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Related legal case
Brad H. v. The City of New York
| Year | 2011 |
|---|---|
| Cite | 17 N.Y.3d 180, 951 N.E.2d 743 (N.Y. 2011) |
| Level | State Court of Appeals |
| Injunction Status | N/A |