E-Alert Case Updates
Delaware Federal Court Examines the Requirements for Organizational Standing Under the Protection and Advocacy for Individuals with Mental Illness Act
Community Legal Aid Society, Inc. v. Robert M. Coupe
Community Legal Aid Society, Inc. v. Robert M. Coupe involved a civil rights lawsuit filed by a community advocacy group against the Commissioner of the Delaware Department of Correction regarding the treatment of prisoners with mental illness. The Commissioner filed a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(l), on the basis that the advocacy group lacked standing to bring the action. The United States District Court for the District of Delaware concluded that the advocacy group met the requirements for organizational standing under the Protection and Advocacy for Individuals with Mental Illness Act, 42 U.S.C. § 10801, et seq. Thus, the Court denied the Commissioner’s motion to dismiss for lack of standing.
By way of factual background, on August 6, 2015, Plaintiff Community Legal Aid Society, Inc. ("CLASI'') filed a Complaint alleging that Defendant Robert M. Coupe ("Coupe"), the Commissioner of the Delaware Department of Correction ("DOC"), violated the Eighth Amendment and the Delaware Constitution by confining prisoners with mental illness in solitary confinement, without providing proper medical and mental health treatment and without allowing adequate out-of-cell time. The Complaint sought declaratory and injunctive relief. On October 1, 2015, Coupe filed a motion to dismiss all of CLASI's claims pursuant to Federal Rule of Civil Procedure 12(b)(l), on the basis that CLASI lacked standing to bring the action solely on its behalf.
The Court began its analysis by noting that “a motion to dismiss for want of standing is ... properly brought pursuant to Rule 12(b)(l), because standing is a jurisdictional matter." See Ballentine v. United States, 486 F.3d 806, 810 (3d Cir. 2007). The Court explained that a district court must determine whether a Rule 12(b)(l) motion presents a "facial" attack or a "factual" attack on the claim at issue. See In re Schering Plough Corp., 678 F.3d 235, 243 (3d Cir. 2012). The Court noted that Coupe's motion raised a facial attack on subject matter jurisdiction, and therefore, the Court would apply the same standard of review it would use in considering a motion to dismiss under Rule 12(b)(6), by construing the alleged facts in favor of the nonmoving party. See Constitution Party of Pennsylvania v. Aichele, 757 F.3d 347, 357-58 (3d Cir. 2014).
CLASI argued that it met the requirements for organizational standing as the Protection and Advocacy System ("P&A") for the State of Delaware under the Protection and Advocacy for Individuals with Mental Illness Act, 42 U.S.C. § 10801 et seq. ("PAIMI"). Thus, the Court noted that it was required to consider whether CLASI met both the statutory and constitutional requirements for standing.
The Court explained that in Hunt v. Washington State Apple Advertising Commission, 432 U.S. 333, 343 (1977), the Supreme Court held that an association has standing to sue on behalf of its members when: "(a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization's purpose; and (c) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit." The Court noted that the first two (2) requirements were constitutional, while the third was "prudential" and could be abrogated by statute. See United Food & Comm. Workers Union Local 751 v. Brown Grp., 517 U.S. 544, 557-58 (1996). The Court found that, in this case, the third Hunt requirement was not applicable in light of the role Congress assigned under PAIMI to advocacy organizations such as CLASI. See Oregon Advocacy Ctr. v. Mink, 322 F.3d 1101, 1113 (9th Cir. 2003) (holding that by authorizing PAIMI P&As to sue on behalf of individuals with mental illness, Congress abrogated the third, prudential standing requirement). Thus, the Court considered only the first two (2) Hunt requirements.
The Court explained that, under Hunt, an organization may have standing to sue on behalf of its constituents if its constituents possess "all of the indicia of membership in an organization." See Hunt, 432 U.S. at 395. The Court further explained that PAIMI required that the governing board of a PAIMI P&A "shall be composed of ... members ... who broadly represent or are knowledgeable about the needs of the clients served by the system," where such members are defined to include "individuals who have received or are receiving mental health services and family members of such individuals." See 42 U.S.C. § 10805(c)(l)(B). Also, a PAIMI P&A must:
See 42 U.S.C. §§ 10805(a)(6)-(9).
In its Complaint, CLASI averred that it had been Delaware's PAIMI P&A since PAIMI was enacted in 1986. Accordingly, CLASI claimed that it established an advisory council, interviewed mentally ill prisoners, evaluated the records of mentally ill prisoners with the aid of a psychiatrist, discussed deficiencies in DOC’s treatment of prisoners with serious mental illness with Coupe's counsel, and has members who broadly represent or are knowledgeable about the needs of mentally ill prisoners. Considering the facts in the light most favorable to CLASI, the Court accepted CLASI’s assertions as true.
CLASI further averred that it met the second Hunt factor because protecting and advocating for people with mental illness was central to CLASI's statutory purpose. See 42 U.S.C. § 1080l(b). The Court agreed that CLASI met the second Hunt requirement. The Court explained that, considering the facts asserted in the light most favorable to CLASI, its constituents possessed the indicia of a membership organization, thereby establishing organizational standing. See Doe v. Stincer, 175 F.3d 879, 886 (11th Cir. 1999) (holding that a PAIMI organization "may sue on behalf of its constituents like a more traditional association may sue on behalf of its members").
For the foregoing reasons, the Court denied Coupe's motion to dismiss for lack of standing.
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