The Matter of Mental Hygiene Legal Service v. Kerry Delaney
This case involves an appeal by Mental Hygiene Legal Service on behalf of a 16-year-old child with developmental disabilities who was confined to an emergency room for several weeks due to a lack of suitable residential placement or in-home services. Petitioner sought the child's immediate discharge and a declaration that the state's failure to provide community habilitation and respite services was arbitrary and violated her statutory rights under CPLR articles 70 and 78, and the Americans with Disabilities Act. The lower courts dismissed the petition, finding the matter moot but applying the exception. The Court of Appeals ultimately dismissed the appeal on grounds of mootness, citing intervening material alterations to service programs, specifically the Crisis Services for Individuals with Intellectual and/or Developmental Disabilities (CSIDD) program. A dissenting opinion argued for the application of the mootness exception and the viability of petitioner's claims under state and federal law.