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Z.P. v. Yale University

United States District Court, D. Connecticut

September 19, 2019

Z.P., Plaintiff,
v.
YALE UNIVERSITY, YALE NEW HAVEN HOSPITAL, PETER SALOVEY, PAUL GENECIN, LORRAINE SIGGINS, JONATHAN HOLLOWAY, JOHN DOES 1-3, JANE DOES 1-3, Defendants.

          MEMORANDUM OF DECISION ON DEFENDANTS' MOTION TO DISMISS

          WARREN W. EGINTON SENIOR UNITED STATES DISTRICT JUDGE

         This is an action by a former Yale University student who was hospitalized and required to take leave during her senior year of college. Plaintiff alleges violation of the Americans with Disabilities Act (Count I), the Rehabilitation Act of 1973 (Count II), and the Fair Housing Amendments Act (Count III). Plaintiff further alleges common law invasion of privacy (Count IV), breach of the duty of confidentiality (Count V), and violation of Connecticut General Statutes § 17a-506, regarding hospital confinement (Count VI).

         Defendants have moved to dismiss Counts I, IV, and VI in their entirety; Count II as to the individual defendants; Count III as to Yale New Haven Hospital, Dr. Paul Genecin, and Dr. Lorraine Siggins; Count V as to Yale University, Peter Salovey, Jonathan Holloway, and Dr. Paul Genecin; the request for punitive damages in relation to Counts II, IV, V, and VI; and the request for attorneys' fees in relation to all counts. For the following reasons, defendants' motion will be granted.

         BACKGROUND

         The following allegations were taken from plaintiff's complaint. Plaintiff has a history of clinical depression. In her senior year at Yale University, after a spate of suicides on campus, plaintiff discussed her emotions with her religious advisor, who suggested that she seek medical advice from Yale Mental Health and Counseling. Yale Mental Health and Counseling, in turn, advised plaintiff to seek admission to Yale New Haven Hospital for treatment.

         Plaintiff was advised that if she admitted herself into the Hospital, she would meet with a treatment team on the next business day, but she was never advised that she could be held involuntarily after admission. Nevertheless, Yale New Haven Hospital applied to commit plaintiff involuntarily. No one advised plaintiff of her right to leave after giving the Hospital three days' notice of such desire pursuant to Connecticut General Statutes § 17a-506.

         Plaintiff's parents arrived shortly after plaintiff was admitted to the Hospital. The Hospital advised plaintiff's parents that plaintiff was admitted via a “physician's emergency certificate” and that she could be kept by the Hospital for an additional two weeks. Plaintiff's parents requested documentation on their daughter's right to challenge her involuntary admission. Despite their efforts, neither plaintiff nor her parents were able to obtain a “physician's emergency certificate” or other information about plaintiff's right to challenge to her involuntary admission.

         In light of recent suicides on campus, defendants determined that plaintiff should take a medical leave from school due to her mental health. This decision was made despite plaintiff's assertions that her mood and coping skills had improved.

         Plaintiff appealed the decision to place her on medical leave, noting that Yale was a refuge from her stressful home environment, more conducive to her recovery. Jonathan Holloway, then Dean of Yale College, denied plaintiff's appeal. Plaintiff further alleges that, in the process of forcing her to take leave, the Hospital disclosed confidential medical information to one or more of the Yale University defendants.

         On November 17, 2016, plaintiff was released from the Hospital. She was not permitted to finish the fall 2016 semester or to start the spring 2017 semester and was forced to vacate her campus residence. Defendants' actions prevented plaintiff from graduating with her class. Plaintiff was permitted return to school for the fall 2017 semester.

         DISCUSSION

         The function of a motion to dismiss is "merely to assess the legal feasibility of the complaint, not to assay the weight of the evidence which might be offered in support thereof." Ryder Energy Distribution v. Merrill Lynch Commodities, Inc., 748 F.2d 774, 779 (2d Cir. 1984). When deciding a motion to dismiss, the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in favor of the pleader. Hishon v. King, 467 U.S. 69, 73 (1984). The complaint must contain the grounds upon which the claim rests through factual allegations sufficient “to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). A plaintiff is obliged to amplify a claim with some factual allegations in those contexts where such amplification is needed to render the claim plausible. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

         Count I - Americans with Disabilities Act

         Defendants argue that monetary damages are not available to a private plaintiff under Title III of the ADA. Plaintiff ...


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