Gormley v. Wood-El

Plaintiff Lorraine Gormley was an attorney employed by the Department of the Public Advocate, Division of Mental Health Advocacy, providing legal representation to clients involuntarily committed in state psychiatric facilities, including Ancora Psychiatric Hospital. Each ward at Ancora contained a day room in which up to forty patients could congregate. Visiting attorneys and psychiatrists also were required to use the day rooms for professional interviews. Although frequent violence occurred in the day rooms, no security guards or cameras were posted there. While at Ancora, Gormley met for the first time with her client B.R., a 21-year-old woman committed sixteen days earlier for a “psychotic disorder” that induced hallucinations. At the start of the interview in the hospital’s crowded and chaotic day room, B.R. violently attacked Gormley in the presence of hospital staff. Gormley filed a civil action against Ancora’s CEO, LaTanya Wood-El, and other government officials, in their individual capacities, under both the Federal Civil Rights Act and the New Jersey Civil Rights Act, alleging that her constitutional right to be free from state-created danger was violated. On defendants’ motions for summary judgment, the trial court concluded that Gormley had presented sufficient evidence to proceed on the civil-rights claims under the state-created-danger doctrine. The court deferred deciding whether she was entitled to injunctive relief. The issue before the Supreme Court in this case was whether injuries Gomley suffered resulted from a state-created danger that violated her substantive-due-process rights under the Fourteenth Amendment of the United States Constitution and whether defendants were entitled to qualified immunity. Under the facts of this case, the Supreme Court concluded that the lawyer had a substantive-due-process right to be free from state-created dangers. Because that right was clearly established at the time the lawyer was attacked, the state official defendants were not entitled to qualified immunity. View "Gormley v. Wood-El" on Justia Law