J.R. v. Hansen, No. 12-14212 (11th Cir. 2015)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983, claiming that Florida law denies due process because it permits the State to keep intellectually disabled people like him involuntarily committed indefinitely without periodic review. The district court concluded that the statutory scheme was constitutional, concluding that Fla. Stat. 393.11 contains an implicit requirement that if a committed person no longer meets the admission criteria, the APD must petition the circuit court to order release. The court certified questions to the Florida Supreme Court about Florida’s scheme for the involuntary commitment of the intellectually disabled. Florida law contains no requirement, explicit or implicit, that the APD review the continuing commitment of intellectually disabled persons. Neither does Florida law require that the APD petition the admitting circuit court to release a person who no longer meets the criteria for commitment. Therefore, the court held that Florida's statutory scheme is unconstitutional because it does not provide periodic review of the propriety of ongoing commitment by someone with the duty to consider and the authority to order release when appropriate. The court noted that it is sympathetic to the State of Florida’s interest in involuntarily admitting the intellectually disabled to residential services in order to “prevent or reduce the severity of developmental disabilities” and to “enable individuals with developmental disabilities to achieve their greatest potential for independent and productive living.” Accordingly, the court reversed and remanded.
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