United States District Court, D. Connecticut
MEMORANDUM OF DECISION ON DEFENDANTS' MOTION TO
W. EGINTON SENIOR UNITED STATES DISTRICT JUDGE
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).
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.
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.
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.
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
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
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.
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.
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).
I - Americans with Disabilities Act
argue that monetary damages are not available to a private
plaintiff under Title III of the ADA. Plaintiff ...