D.L. v. Sheppard Pratt Health Sys.

D.L. v. Sheppard Pratt Health System Inc., et al., No. 38, September Term, 2018. Opinion by Getty, J. ACTION—GROUNDS AND CONDITIONS PRECEDENT—MOOT, HYPOTHETICAL OR ABSTRACT QUESTIONS The Court of Appeals held that a juvenile’s petition for judicial review of her involuntary admission was not moot based simply upon her release. The involuntary admission subjected the juvenile to sufficient possible collateral consequences to justify judicial review of her involuntary admission, despite her release. Circuit Court for Howard County Case No. 13-C-15-103393 Argued: January 4, 2019 IN THE COURT OF APPEALS OF MARYLAND No. 38 September Term, 2018 D.L. v. SHEPPARD PRATT HEALTH SYSTEM, INC., et al., Barbera, C.J. *Greene, McDonald, Watts, Hotten, Getty, Rodowsky, Lawrence F. (Senior Judge, Specially Assigned), JJ. Opinion by Getty, J. Filed: August 13, 2019 *Greene, J., now retired, participated in the hearing and conference of this case while active an member of this Court; after being recalled pursuant to the Pursuant to Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic. Maryland Constitution, Article IV, Section 3A, he 2019-08-13 14:23-04:00 also participated in the decision and adoption of this opinion. Suzanne C. Johnson, Clerk In 2015, an Administrative Law Judge (“ALJ”) involuntarily admitted Petitioner, D.L., to a facility operated by Respondent, Sheppard Pratt Health Systems, Inc. (“Sheppard Pratt”) in Ellicott City, Maryland. After D.L. was released from Sheppard Pratt, she filed a petition for judicial review in the Circuit Court for Howard County challenging her involuntary admission. Without holding a hearing, the circuit court granted Sheppard Pratt’s motion to dismiss on grounds of mootness because D.L. had already been released from the facility. Accordingly, the primary issue within this case is whether judicial review of an ALJ’s involuntary admission decision is mooted by the juvenile’s release.1 Ultimately, we hold that D.L. is subject to collateral consequences stemming from her involuntary admission and, therefore, the circuit court erred in dismissing the case as moot. In accordance with this determination, we remand the case to the circuit court for further proceedings on D.L.’s petition for judicial review. Although D.L. also presents us with an issue of whether the Court of Special Appeals erred in determining she failed to preserve the capable of repetition yet evading review exception to the mootness doctrine, we need not resolve this inquiry based on our conclusion regarding collateral consequences. 1 We note that D.L. did not present this Court with the meritorious issue of her petition for judicial review, i.e. whether a less restrictive form of intervention was available. Therefore, we are merely tasked with determining whether the circuit court erred in dismissing D.L.’s petition for judicial review as moot. More information on this unique procedural posture will be provided throughout our analysis. BACKGROUND A fourteen-year-old girl, D.L., presented at the emergency department of MedStar Southern Maryland Hospital (“MedStar Southern”) with fresh cut wounds along her left arm stretching from her elbow to her wrist. In addition to the new cuts, the arm ...

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