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U.S. v. DISTRICT OF COLUMBIA

March 31, 1999

UNITED STATES OF AMERICA, PLAINTIFF,
v.
DISTRICT OF COLUMBIA, ET AL., DEFENDANTS.



The opinion of the court was delivered by: Urbina, District Judge.

MEMORANDUM OPINION

Granting the Plaintiff's Motion for Summary Judgment; Denying
  the Defendants' Motions for Summary Judgment

I. BACKGROUND

This action commenced on March 29, 1995, when the United States of America (hereinafter "plaintiff") filed a complaint against the District of Columbia and Mr. Bennett seeking release of the psychiatric records of a group of patients who had been committed to Saint Elizabeths Hospital (hereinafter "St. Elizabeths") pursuant to D.C.Code Ann. § 24-301(d)(1) after having been found not guilty of federal crimes by reason of insanity. In the original complaint, the plaintiff alleged that it was entitled to access the patients' psychiatric records pursuant to 24 U.S.C. § 225f, which provided for the transfer to the District of Columbia of "all right, title, and interest of the United States in all real property at Saint Elizabeths Hospital. . . ." 24 U.S.C. § 225f(a)(1). During the pendency of this litigation, however, Congress amended 18 U.S.C. § 4243 to include a provision that specifically grants the plaintiff access to the records sought. See Title III of the Economic Espionage Act of 1996, Pub.L. No. 104-294, § 301, 110 Stat. 3488, 3494-95 (Oct. 11, 1996) (hereinafter "Title III"). Consequently, the plaintiff now relies primarily on Title III to support its allegation of entitlement to the patients' psychiatric records.

Both the District of Columbia and the patients whose records are being sought (hereinafter collectively referred to as "defendants") contend that the plaintiff is not legally entitled to the records. Consequently, on November 8, 1996, the patients filed a complaint seeking a declaration that the provision of Title III that grants the plaintiff access to their records (hereinafter "access provision") is unconstitutional and seeking an injunction barring St. Elizabeths from releasing their records. The patients also seek a declaration that a separate provision of Title III, which provides for the transfer of the patients themselves into the custody of the Attorney General, (hereinafter "transfer provision") is unconstitutional. In addition, they seek an injunction barring the plaintiff from attempting to obtain custody of the patients.

On November 20, 1996, the court granted the patients' motion for a temporary restraining order, thus barring the plaintiff from either accessing the records or attempting to obtain custody of the patients. Subsequently, the court consolidated the plaintiff's original complaint and the complaint later filed by the patients into the action currently before the court.

II. LEGAL STANDARD FOR SUMMARY JUDGMENT

All parties to this action have filed motions for summary judgment. Summary judgment is appropriate upon a finding that "there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Fed.R.Civ.P. 56(c). The substantive law upon which a claim rests determines which facts are "material." See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). If a fact bears upon an essential element of the legal claim, then it is material; otherwise, it is not. See id.; Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). Only disputes over facts that can establish an element of the claim, and thus might affect its ultimate resolution, can create a "genuine issue" sufficient to preclude summary judgment. See Anderson, 477 U.S. at 248, 106 S.Ct. 2505; Celotex, 477 U.S. at 322, 106 S.Ct. 2548.

To prevail on a motion for summary judgment, the moving party bears the burden of establishing that there are no genuine issues of material fact and that the nonmoving party has failed to offer sufficient evidence to support a valid legal claim. See Anderson, 477 U.S. at 256, 106 S.Ct. 2505; Celotex, 477 U.S. at 325, 106 S.Ct. 2548. In ruling on the motion, the court must accept the evidence of the nonmoving party as true and must draw all justifiable inferences in favor of the nonmoving party. See Anderson, 477 U.S. at 255, 106 S.Ct. 2505. It is not sufficient, however, for the nonmoving party to establish "the mere existence of a scintilla of evidence in support of the [nonmoving party's] position . . .; there must be evidence on which the jury could reasonably find for the [nonmoving party]." Id. at 252, 106 S.Ct. 2505. If the evidence in favor of the nonmoving party "is merely colorable, or is not significantly probative, summary judgment may be granted." Id. at 249-50, 106 S.Ct. 2505 (internal citations omitted).

In this case, the court concludes that there are no genuine issues of material fact and that the plaintiff is entitled to judgment as a matter of law. Accordingly, the plaintiff's motion for summary judgment will be granted and the defendants' motions for summary judgment will be denied.

III. DISCUSSION

A. Legislative History

The Insanity Defense Reform Act, 18 U.S.C. § 4243, which Congress enacted in 1984, provides for the mandatory hospitalization of defendants found not guilty of federal crimes by reason of insanity. Even prior to the enactment of 18 U.S.C. § 4243, however, defendants charged with federal crimes in the District of Columbia who were found not guilty by reason of insanity were automatically committed to a hospital for the mentally ill. These defendants were committed to St. Elizabeths pursuant to D.C.Code Ann. § 24-301(d)(1), which provides as follows:

  If any person tried upon an indictment or information
  for an offense raises the defense of insanity and is
  acquitted solely on the ground that he was insane at
  the time of its commission, he shall be committed to
  a hospital for the mentally ill until such time as he
  is eligible for release. . . .

It was pursuant to D.C.Code Ann. § 24-301(d)(1) that all of the patients who are parties to this action were committed to St. Elizabeths.

From 1855 until 1987, St. Elizabeths was owned and operated by the United States government. See 24 U.S.C. § 225, 225f. On October 1, 1987, however, Congress transferred ownership and control of St. Elizabeths to the District of Columbia. See 24 U.S.C. § 225f. Nevertheless, the United States remained financially responsible for all patients committed to St. Elizabeths as a result of having been found not guilty of federal crimes by reason of insanity. See 24 U.S.C. § 225g(b)(1)(C) (directing the United States to pay "the full costs for the provision of mental ...


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