Involuntarily Committed Plaintiff Loses State Court Case Against Hospital Based on Federal Court's Prior Dismissal

Case: Capellupo v. Nassau Health Care Corp.

Court: Supreme Court, Appellate Division, Second Department, New York

Date: 7/11/12

From: New York attorney Gary E. Rosenberg (personal injury and accident attorney and lawyer; serving Brooklyn and Queens; Queens injury attorney)

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Facts: Not an accident case here. This plaintiff ran afoul of the Nassau County Police Dept. and was hospitalized involuntarily, on a psychiatric hold, in Nassau County Medical Center for 16 days.

After plaintiff got out of the hospital, he sued in U.S. Federal Court (the appeal that is the subject of this blog was taken in a N.Y. State Court case) His case was brought against Nassau County, the police department and the hospital for false imprisonment, false arrest and such.

The Federal Court found that plaintiff's rights had not been violated. Particularly, the Court decided that plaintiff posed a danger to himself or others so that his psychiatric hold was correct.

Suing in State Court, plaintiff set down the same basic claims as he had in Federal Court, with an added medical malpractice cause of action.

The hospital was left as the only defendant after plaintiff voluntarily dropped his claims against the other defendants.

The hospital moved to dismiss this lawsuit on the ground of a legal technicality known as "collateral estoppel." The basis of the hospital's argument was that the Federal Court's findings could be used by the hospital in the State Court action so that the State Court lawsuit, too, should be dismissed.

Partly agreeing with the hospital the lower State Court dismissed all the plaintiff's claims except those for false imprisonment, false arrest, and intentional infliction of emotional distress. The lower State Court reasoned that the Federal Court has not reached these three of plaintiff's claims.

Held: In finding that the involuntary commitment of plaintiff was correct, the Federal Court foreclosed the undismissed causes of action. By reason of "collateral estoppel," the rest of plaintiff's claim, and his lawsuit, are dismissed.

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