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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 03-18-00740-CV
Regular Panel Decision
Mar 06, 2020

Gerard Matzen// Marsha McLane, in Her Official Capacity as Director of Texas Civil Commitment Office, and the Texas Civil Commitment Office v. Marsha McLane, in Her Official Capacity as Director of Texas Civil Commitment Office, and the Texas Civil Commitment Office// Cross-Appellee, Gerard Matzen

Gerard Matzen appealed a district court's partial grant of Appellees' plea to the jurisdiction in his civil commitment case under the sexually violent predator (SVP) statute, challenging rulings on his APA, ultra vires, and immunity claims. The Texas Civil Commitment Office (TCCO) and its Director Marsha McLane cross-appealed the denial of their plea regarding Matzen's procedural due process and takings claims. The Court of Appeals affirmed the district court's order, finding Matzen's APA and ultra vires claims invalid and qualified immunity inapplicable. However, the court upheld the district court's denial of the plea concerning Matzen's procedural due process and takings claims, concluding they presented viable constitutional questions requiring further factual development.

Civil commitmentSexually Violent Predator ActPlea to the jurisdictionSovereign immunityUltra vires claimsAdministrative Procedure ActDue processTakings clauseCost recovery feesGovernment agency authority
References
65
Case No. 02-18-00019-CV
Regular Panel Decision
Feb 28, 2019

in Re: The Commitment of Gregory A. Jones

Gregory A. Jones appealed the trial court's order committing him as a sexually violent predator. Psychologists Jason Dunham and Sheri Gaines evaluated Jones, testifying to his behavioral abnormality and likelihood to commit sexually violent offenses based on his criminal history, risk factors, and test results. The jury found Jones to be a sexually violent predator. The Court of Appeals found the evidence legally sufficient but reversed and remanded the case for a new trial. The reversal was due to the trial court's error in denying Jones's request for a jury instruction allowing a non-unanimous (10-2) verdict for a 'no' finding, which is permissible under civil procedure rules for non-affirmative determinations.

Sexually Violent PredatorCivil CommitmentJury InstructionLegal SufficiencyBehavioral AbnormalityRisk AssessmentRecidivismExpert TestimonyForensic PsychologyCriminal History
References
30
Case No. M2000-02785-COA-R3-CV
Regular Panel Decision
Feb 07, 2002

Rene Mercer v. HCA Health Services of TN, Inc.

A widow and her children claimed negligence against a hospital and a psychiatrist after her husband's suicide, alleging premature release from involuntary commitment. The trial court granted summary judgment to the defendants, ruling that the hospital had a duty to release the patient as ordered by the psychiatrist, and the psychiatrist was entitled to absolute immunity for actions under involuntary commitment statutes. The Court of Appeals reversed this decision, finding that the question of negligence against both defendants deserved further inquiry and that physicians involved in involuntary commitment do not qualify for judicial immunity. The court emphasized that public policy and existing medical malpractice statutes adequately address concerns regarding physician liability in such cases.

SuicideNegligenceMedical MalpracticeInvoluntary CommitmentPsychiatric CareHospital LiabilityPhysician ImmunitySummary JudgmentStandard of CareMental Health
References
14
Case No. 09-06-180 CV
Regular Panel Decision
Jul 12, 2007

in Re Commitment of Michael Marks

Michael Marks appealed a civil commitment order issued under the Sexually Violent Predator Act, after a jury found him to be a sexually violent predator. Marks challenged the trial court's exclusion of his expert witnesses, Dr. Jason Dunham and psychotherapist Sara Smith, citing improper disclosure and the failure to hold a gatekeeper hearing for the State's expert, Dr. Michael Arambula. He also alleged improper closing arguments by the State. The Court of Appeals affirmed the lower court's judgment, concluding that Marks failed to timely disclose expert testimony, did not properly request a gatekeeper hearing, and waived objections to the closing arguments.

Civil CommitmentSexually Violent Predator ActExpert Witness ExclusionDiscovery RulesGatekeeper HearingClosing ArgumentAbuse of DiscretionAppellate ProcedureMental IllnessSchizoaffective Disorder
References
16
Case No. NO. 09-13-00513-CV
Regular Panel Decision
Dec 11, 2014

in Re Commitment of Alonzo May

Alonzo May appealed from a jury verdict civilly committing him as a sexually violent predator under the Texas Health & Safety Code Ann. §§ 841.001-.151. May raised two issues: the trial court's striking of his counterclaim for declaratory judgment regarding the statute's unconstitutionality, and its alleged failure to properly take judicial notice of two U.S. Supreme Court cases, leading to denied jury instruction requests. The Court of Appeals found May's issues without merit. It affirmed the trial court's decision to strike the counterclaim, noting May could and did raise constitutionality as an affirmative defense. The court also held that the trial court properly took judicial notice of the law and did not abuse its discretion in refusing May's proposed jury instructions, as the given charge closely tracked the statutory language.

Civil CommitmentSexually Violent PredatorConstitutional LawJury InstructionsStatutory InterpretationAffirmative DefenseJudicial NoticeAppellate ReviewTexas Court of AppealsHealth and Safety Code
References
11
Case No. 47 Tex. Sup. Ct. J. 1028
Regular Panel Decision
Sep 03, 2004

In Re Commitment of Fisher

This case involves the civil commitment of Michael James Fisher as a sexually violent predator under the Texas Civil Commitment of Sexually Violent Predators Act. The Supreme Court of Texas addresses whether the Act is punitive or civil, concluding that it is civil based on legislative intent and its non-punitive effects, despite provisions for criminal penalties for violations of commitment conditions. The opinion also rejects Fisher's arguments regarding the right to be competent at trial in a civil commitment proceeding, Fifth Amendment self-incrimination, and facial vagueness challenges to the Act's "behavioral abnormality" definition and individualized treatment. The Court reversed the court of appeals' judgment, which had found the Act punitive and unconstitutional, and affirmed Fisher's civil commitment.

Sexually Violent Predator ActCivil CommitmentDue ProcessConstitutional LawPunitive vs. CivilBehavioral AbnormalityMental CompetencyFifth AmendmentVagueness ChallengeOutpatient Treatment
References
54
Case No. MISSING
Regular Panel Decision

Mercer v. HCA Health Services of Tennessee, Inc.

A widow's husband committed suicide after being prematurely discharged from involuntary commitment at Summit Medical Center, operated by HCA Health Services, by psychiatrist Dr. Steven Nyquist. The widow, Rene Mercer, sued both Dr. Nyquist and HCA for negligence. The trial court granted summary judgment to both defendants, finding HCA had a duty to release the patient as ordered and Dr. Nyquist was entitled to absolute immunity. The appellate court reversed the trial court's decision, concluding that physicians involved in involuntary commitment proceedings are not entitled to judicial immunity and that there were sufficient allegations of negligence against HCA. The case was remanded for further proceedings.

SuicideNegligenceMedical MalpracticeHospital LiabilityPsychiatrist LiabilityInvoluntary CommitmentJudicial ImmunityQuasi-Judicial ImmunitySummary JudgmentStandard of Care
References
14
Case No. MISSING
Regular Panel Decision

King v. Carey

Plaintiffs, a class of minors civilly committed to New York State Division for Youth camps as juvenile delinquents or persons in need of supervision, allege that various state officials have violated their constitutional right to be free from involuntary servitude and various sections of the Fair Labor Standards Act. They seek declaratory, injunctive, and damage relief. Defendants moved to dismiss the claims, arguing Eleventh Amendment immunity and that no constitutional rights were violated, and challenged the applicability of the Thirteenth Amendment and FLSA to civilly committed juveniles. They also opposed class certification. The court denied the motions to dismiss, finding no Eleventh Amendment bar to prospective injunctive relief or individual liability, and that the Thirteenth Amendment and FLSA could apply to civilly committed individuals based on the allegations of excessive work. The court also granted class certification for the involuntary servitude and declaratory judgment under FLSA claims, but denied class action treatment for FLSA damages due to statutory limitations.

Juvenile DelinquencyInvoluntary ServitudeFair Labor Standards ActCivil CommitmentClass Action CertificationEleventh AmendmentThirteenth AmendmentFederal Court JurisdictionProspective Injunctive ReliefQualified Immunity
References
18
Case No. MISSING
Regular Panel Decision

Bell Aircraft Corp. v. Siegler

The court affirmed both the final and intermediate orders without costs in this matter. The case primarily involved an appeal from an order that had found several defendants guilty of criminal contempt of court. Additionally, the appeal also addressed an order which denied a motion seeking to resettle an order of commitment. Furthermore, a motion to vacate and perpetually stay the orders of commitment was also denied. All presiding judges concurred with the decision.

Criminal ContemptOrder of CommitmentResettlement MotionVacate MotionStay OrdersAppellate ReviewOrder AffirmedJudicial Concurrence
References
1
Case No. MISSING
Regular Panel Decision

Harrison v. State

Millet Harrison, Jr., who was found not guilty of murder by reason of insanity in 1994, appealed a December 10, 2003 order extending his inpatient mental health services. He contended that the evidence was legally and factually insufficient to support the trial court's finding that he continued to meet the criteria for involuntary commitment. The court reviewed the criteria for involuntary commitment and the evidence presented by expert witnesses Dr. David Self and Dr. Edward Gripon, as well as Harrison's own testimony and that of his family. The evidence indicated that Harrison's paranoid schizophrenia was in full remission due to medication, and that he had a strong history of compliance when medication was prescribed. Both doctors recommended his release to a less restrictive environment with intensive outpatient monitoring. The appellate court found that the trial court's finding that outpatient supervision was not appropriate was unsupported by the record, therefore reversing the judgment and remanding the case for further proceedings.

Mental HealthInvoluntary CommitmentInsanity DefenseParanoid SchizophreniaMedication ComplianceOutpatient TreatmentAppellate ReviewLegal SufficiencyFactual SufficiencyTexas Law
References
16
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