Thursday, May 23, 2013

Zinermon v. Burch case brief

Zinermon v. Burch case brief
494 U.S. 113, 110 S. Ct. 975, 108 L. Ed. 2d 100 (1990)

CASE SYNOPSIS:
A patient brought suit against the petitioners, physicians, hospital administrators, staff members, and others, for an alleged violation of his due process rights.
-The United States Court of Appeals for the Eleventh Circuit reversed the district court's dismissal under Fed. R. Civ. P. 12(b)(6) and remanded the case.
-The physicians and others appealed.

FACTS:
-The physicians and other defendants argued that the patient's complaint failed to state a claim under § 1983 because it alleged only a random, unauthorized violation of the Florida statutes governing admission of mental patients.
-The patient alleged that petitioners deprived him of his liberty, without due process of law, by admitting him to the hospital as a "voluntary" mental patient when he was incompetent to give informed consent to his admission.
-The Court affirmed the judgment reversing dismissal. 

-In doing so, the Court resolved a conflict in the courts of appeals over the proper scope of the Parratt v. Taylor rule.

HOLDING:
The Court held that the Parratt rule did not control the case because there was no necessity for quick action by the physicians and others, nor was providing pre-deprivation process impractical.

ANALYSIS:
The case required a general Mathews doctrine analysis because it was not a special case, like Parratt, where post-deprivation tort remedies provided all the process due when they were all the state could have been expected to provide.
-Thus, the patient did state a claim under § 1983, and the judgment was affirmed and remanded.

CONCLUSION: The judgment reversing the dismissal of the patient's complaint was affirmed and remanded for a decision on the merits.

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