Justices Say Superior Court Lacked Jurisdiction in Involuntary Commitment Case
The Pennsylvania Supreme Court has ruled that the Superior Court erred when it heard the appeal of a man whose gun ownership was curtailed because of an involuntary mental health hospitalization.
October 17, 2019 at 03:18 PM
4 minute read
The Pennsylvania Supreme Court has ruled that the Superior Court erred when it heard the appeal of a man whose gun ownership was curtailed because of an involuntary mental health hospitalization.
In an Oct. 15 opinion authored by Supreme Court Justice Debra Todd, the court reversed the Superior Court's ruling in favor of petitioner J.M.Y. in In re Petition of J.M.Y. Chief Justice Thomas Saylor filed a concurring opinion.
J.M.Y. brought the case claiming his due process rights had been violated when a trial court declined to expunge his mental health records because his commitment was not valid under the law. The Superior Court en banc ultimately reversed that decision 8-1.
Now, considering only whether the Superior Court had jurisdiction to hear the appeal, the tables were turned once more by the high court. Todd said the fact that J.M.Y. filed his appeal too late meant the Superior Court could not hear the case.
J.M.Y. "had 30 days from the date of the mental health review officer's certification to petition the court of common pleas for review of any due process or other challenges to the certification," Todd said. "As he did not do so, but instead filed the instant petition over two years later, neither the court of common pleas nor the Superior Court had jurisdiction to consider the merits of these claims. Accordingly, we must reverse the order of the Superior Court, which itself reversed the common pleas court's order dismissing appellee's petition."
In his one-page concurrence, Saylor agreed with the ruling but took issue with the majority's view of jurisdiction.
"Since subject matter jurisdiction connotes 'the competency of the court to determine controversies of the general class to which the case presented for consideration belongs' it is quite tenuous, in my view, to treat time deadlines as implicating a court's subject matter jurisdiction," Saylor said.
According to Superior Court Judge Jacqueline Shogan's majority opinion, J.M.Y. got drunk at a fraternity party at the University of Pittsburgh in 2012. He was on medication for depression and anxiety, and he was apprehended by the police after he attempted to harm himself, Shogan said.
The police took him to Western Psychiatric Hospital, where he was involuntarily committed under Section 302 of the Mental Health Procedures Act, according to Shogan. He was discharged after spending four days there. Sections 302, 303 and 304 prohibit the ownership or use of firearms, which is problematic given the plaintiffs' interest in law enforcement as an occupation. J.M.Y. sought to have the record of his commitment expunged.
During proceedings over the course of 2015, the trial court held that J.M.Y.'s commitment was valid under Sections 302 and 303. However, the Superior Court held that the certification of involuntary commitment was improper and that J.M.Y. was not made aware of the proceedings immediately following his commitment.
"Upon review of the certified record, we conclude that the certification was not proper and, therefore, the Section 303 commitment was not valid," Shogan said. "At the expungement hearing, appellant testified that, although he spoke with a public defender prior to his release from the hospital, he was unaware of any 303 commitment hearing held on September 25, 2012. Appellant testified that he merely 'was told that there could be a hearing.'"
She added, "As indicated by appellant in his appellate brief, our review of the certified record reflects that the trial court failed to address whether there was sufficient evidence to support appellant's Section 302 commitment. Rather than address the underlying Section 302 commitment, the trial court made a determination regarding the validity of appellant's Section 303 commitment."
Judge Judith Ference Olson penned a dissent, arguing that she did not believe the court had jurisdiction to review the commitment.
"Simply stated, no statute provides our courts with jurisdiction to review the sufficiency of appellant's Section 303 commitment or to expunge the record of such commitment—indeed, 42 Pa.C.S.A. Section 5571(b) forbids our exercise of jurisdiction," Olson said.
Terry Despoy of Despoy and Robertson in Hollidaysburg represents J.M.Y. and did not return a call seeking comment. The Pennsylvania State Police declined to comment.
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