Brown v. Stone

66 F. Supp. 2d 412 (1999)

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Brown v. Stone

United States District Court for the Eastern District of New York
66 F. Supp. 2d 412 (1999)

Facts

New York law required the state to provide free psychiatric care and treatment to the indigent. Thus, New York did not bill or sue indigent patients for such care or treatment. However, pursuant to a policy adopted by James Stone (defendant), the commissioner of the New York State Office of Mental Health (OMH), the state asserted counterclaims for payment against indigent patients or former patients who sued the OMH for damages in connection with the care or treatment the patients received from the OMH. Such counterclaims would be contingent on the patients winning their claims against the OMH and limited to the amount awarded to the patients. Limoni Brown (plaintiff), the administrator of the estate of a former indigent patient, sued the OMH regarding the patient’s care. In response, the state asserted a contingent counterclaim against Brown. Brown then sought a declaratory judgment that the OMH’s policy unconstitutionally chilled patients from obtaining compensation for injuries they suffered due to the care and treatment they received from the state, resulting in the OMH pleading contingent counterclaims against Brown. Brown moved to dismiss the OMH’s counterclaims, arguing that New York did not permit contingent counterclaims. The OMH opposed Brown’s motion, citing various New York decisions that it claimed supported the view that contingent counterclaims were permissible.

Rule of Law

Issue

Holding and Reasoning (Block, J.)

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