Klostermann v. Cuomo

John Klostermann, Joanne S., and others (collectively, patients) (plaintiffs) brought two class-action suits against Governor Mario Cuomo, former Governor Hugh Carey, and others (collectively, state) (defendants), claiming that class members were denied their statutory and federal and state constitutional rights to receive assistance upon being discharged from state psychiatric hospitals or were not being released from psychiatric hospitals due to a lack of suitable residential placements. The patients sought declaratory and mandamus relief. The state moved to dismiss the suits on the ground that, among other things, the court did not have subject-matter jurisdiction because the treatment of the mentally ill involved the allocation of resources. Per the state, that was an issue for the executive and legislative branches—not the judiciary—to decide. Both suits were dismissed by the supreme court as being nonjusticiable. The appellate division affirmed in both cases. The patients appealed. In response, the state submitted extensive evidence that the patients’ requested relief would be expensive for the state to provide, assertedly making the patients’ claims not justiciable. The state further argued that even if the claims were justiciable, the courts could not grant the patients’ requested relief because judges could not issue coercive orders (rendering mandamus inappropriate) due to the fact that preparing the requested postdischarge plans and programs were tasks replete with discretion. Additionally, the state contended that a declaratory judgment without an accompanying coercive decree would be meaningless.