Warren Harris v. Muriel Bowser, No. 21-7122 (D.C. Cir. 2023)
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The District of Columbia Department of Behavioral Health had a policy of restraining civilly committed hospital patients during transport to court hearings. It applied that policy to Plaintiff. He says the policy violated his Fifth Amendment right to be free from unjustified bodily restraint. After the superior court granted Plaintiff conditional release, he filed a Section 1983 suit against an assortment of D.C. officials — including the directors of the Department of Corrections and the Department of Behavioral Health. He sought damages for “pain and suffering, degradation, and humiliation” caused by the restraints. The district court granted summary judgment for the D.C. officials.
The DC Circuit affirmed. The court held that Bell and Youngberg each show that the D.C. officials did not violate Plaintiff’s Fifth Amendment rights. The court explained that to show that the restraint policy violated the Constitution under Youngberg, Plaintiff must prove that it was not an exercise of “professional judgment.” The court found that Plaintiff failed to prove either. First, the policy was “made by a professional.” Second, the policy was not a “substantial departure” from the “practices or standards” for transporting civilly-committed patients. Accordingly, the court held that Plaintiff’s claim fails because he offered no evidence to show that the policy was a substantial departure from accepted standards for transporting civilly-committed patients.
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