Mental Health Law Notes 1

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University Of Connecticut *

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5476

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Law

Date

Feb 20, 2024

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5

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Class 9/1 Idea for class discussion: Direct to Consumer Pharmaceutical Advertising https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3278148/ Ringwald v. Prudential Insurance (2010) (disability in part due to mental illness does not qualify for long term disability coverage under the plan) F: P submitted claim for long term disability benefits claiming he was disabled and unable to work due to depression and HIV. I : If a mental illness in combination with a physical illness causes a a participant to be unable to perform any gainful employment, are disability benefits still limited to 24 months? R : The plan indicates that the mental illness limitation of only 24 month of disability coverage applied if the disability is due in whole or part to depression or bipolar disease. H : B/C P inability to work was due in part to mental illness, D did not breach the terms of the Plan by limiting the P benefits to 24 months, and D is entitled to judgment as a matter of law. Had he only been limited to work due to the HIV alone and never mentioned the depression, the plan would have likely extended beyond the 24 months. Class 9/8 The Center Cannot Hold: My Journey Through the Madness (Law professor w/ schizophrenia) Class 3 on negligent treatment and professional liability: CB pp. 148-177(Note 8); 191-201; 208-229; 234(Note 1)-252; 270-288 Class 9/15/22 Malpractice/civil liability Stepakoff v. Kantar (1985) (Instructions on D duty) Claim: That Dr.Kantor breached a duty of care that resulted in the decedent suicide. I: Did the Dr. Breach a duty of care to meet the applicable standard? Standard: Professional Custom Schrempf v. State (1985) (Defenses and Limitions, Professional Judgement Rule) Osheroff v. Chestnut Lodge Inc. (Respectable Minority Doctrine) Merchants Nat. bank v. United States (3 rd party liability) H: There was a duty to a 3 rd party.by the hospital. Tarasoff v. Reg. of UC (3 rd party liability) There is a duty of care to take reasonable care to protect the intended victim.
Against what standard of care is fact finder expected to hold a mental healthcare professional too. Muse v Charter Hospital Addressed a situation where a 16 year old kid with significant depressive and psychosis symptoms had been hospitalized for treatment. Hospital had a policy of discharging patients when insurance ran out. Hospital discharged him. He then took a fatal overdose of his medication and committed suicide. The SC found the hospital liable for wonton negligence. No duty to 3 rd party or actor unless there is a special relationship. Special relationship example: schools. VA Tech Shooting: A senior at VA tech killed 32 student and faculty, wounded 17 others, and then took his own life. This student displayed previous troubling signs. He wrote a paper that included a story about a student that committed a shooting and killed himself. Class 4 on privacy and the duty of confidentiality: CB pp. 372-397; 412-417; 425-430; 478-489 Class 9/22/2022 Class 5 on expert psychiatric testimony: CB pp. 495-513; 516-532; 536-555; 556-570; 624-630; “On being sane in insane places”; additional materials on Rosenhan On Being Sane In Insane Places David L. Rosenhan * Class 9/29/22 United States v. Lewellyn pg 524 - D sought to raise an insanity defense - TC excluded the evidence D wanted to introduce - When do you get to introduce evidence of insanity? o - Compulsive gambling had a causal relationship to his criminal activity. - The court says it needs to pass the general acceptance test o The court decides it does not meet the frye standards and thus it was appropriate that the TC excluded the expert testimony - Mental Health Professionals as Experts
Barefoot v. Estelle (pg 541) What is the role of the adversarial system in qualifying mental health expert testimony? Wisconsin v. Loomis (pg 556) United States v. Edwards pg 625 Class 6 on competency issues in the criminal process: 10/6/22 CB pp. 570-575; 1134-1166(Note 5); 1188-1210(Note 6); 1223-1239 Due process requires in inquiry into competency. Godinez v. Moran pg 1188 - Knowing and voluntary waiver Indiana v. Edwards pg 1200 Ford v. Wainwright pg 1223 (6 rationales for competency requirement in death penalty cases) Criminal Responsibility and the Insanity Defense Pg 631-676, 677-699, 720-724(note 1) Clark v. Arizona (2006) pg 680 The judgment of the state appellate court was affirmed. The Supreme Court of the United States held that Arizona's use of an insanity test stated solely in terms of the capacity to tell whether an act charged as a crime was right or wrong did not violate the Fourteenth Amendment's due process provisions, as there was such fodder for reasonable debate about what the cognate legal and medical tests should be, due process imposed no single canonical formulation of legal insanity. The Court further held that Arizona's test did not raise a proper claim that some constitutional minimum had been shortchanged, for cognitive incapacity was relevant under that test, just as it was under a more extended test, and evidence going to cognitive incapacity had the same significance under both tests. Moreover, the Court ruled that Arizona's restricting consideration of defense evidence of mental illness and incapacity to the evidence's bearing on a claim of insanity. Thus eliminating the evidence's significance directly on the issue of the mental element of the crime charged, did not violate the  Fourteenth Amendment's  due process provisions, because this imposed no restriction on considering observation evidence.
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Class 10/13/2022 - Retributive punishment- debt to society - Utilitarian punishment- keep society safe, general deterrence (setting an example), specific deterrence (prevent this person from continuing the action) - Rehabilitation- reform an offender (ex. Scandanavian country’s) The insanity defense overlaps with these ideas. - W/ regards to retributive punishment, they don’t owe a debt. - From a Utilitarian stance you cant expect an insane person from being deterred by a punishment. - From a rehabilitive stance, it goes to the idea that the individual needs treatment over punishment. M’Naghten Test pg 636- that the individual doesn’t know what they are doing or the wrongfulness of that. Or if they did know, that they did not know what they were doing was wrong. Criticized for being very narrow, did not seem to appreciate the varied ways people can act. “DO they know right from wrong.” Irrestible Impulse Test pg 636- someone might have understood what they would have done but couldn’t control themselves. The Durham Rule pg 637: Fed. Court of Appeals for DC came up with this test the accused is not criminally responsible if the offense was the product of a mental defect. Abandoned the test The American Law Insitiute Test pg 638: Rejection of Medical Model pg 639: A person should be found insane if at the time of his unlawful conduct his mental or emotional processes or behavior controls were impaired to such an extent that he cannot justly be held responsible for his act.” The Heads Case pg 646: Triggered by PTSD, was not convicted for murder by reason of insanity. Pollard Case (Volitional Impairment ) pg 661 - Found to be acting impulsively insane Clark v. Arizona - Individual believed police officer was an alien and killed him. - D wanted to introduce evidence regarding his mental illness to show he was insane and also to show that he did not have the intent to kill the police officer. o TC ruled that the court confined his use of the expert testimony regarding his mental health only for insanity defense and not for the lack of intent mens rea aspect of his defense.
- Insanity defense: mental defect of such severity that they don’t know what they are doing - Court said it is not unconstitutional to eliminate a core aspect of the insanity defense - Regarding the mens rea aspect, the court said that no testimony about mental health diagnosis or symptom can be used to defend ones lack of intent o Each jurisdiction can decide the admissibility of mental health diagnosis for issues outside of insanity defense (like the mens rea component) Class 10/20/22 Pg 744-810 Capital Sentencing Atkins v. Virgina (pg 756) - Categorical exclusions of people with intellectual disabilities Class 10/27/2022 812-856, 861-895 Dodd v. Hughes pg 834 - Police power commitment - Parents part - How and why did dodd seek release from the Nevada state hospital? - Does mental illness recquire something like psychosis to be committed? Matter of Gregorovich pg 840 - Recquires mental illness + dangerousness Whaley v. Jansen Parents patriae commitment: O’Connor v. Donaldson - Parents Patrae case - “A state cant constitutionally confine without more, a non dangerous individual who is capable to surviving safely in freedom by himself or with the helo of willing and responsible family members or friends” (pg 871) -