Filed Date: June 5, 2013
Closed Date: 2014
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On June 5, 2013, thirty-five adult individuals with disabilities filed a lawsuit in the U.S. District Court for the District of New Jersey under the Americans with Disabilities Act ("ADA"), the Rehabilitation Act ("RA"), and the Social Security Act (Medicaid) - as well as a § 1983 constitutional due process claim against the State of New Jersey. The plaintiffs, represented through their legal guardians by private counsel, asked the court for declaratory and injunctive relief to prevent the closing of two residential care facilities where the plaintiffs resided. The claims argued that the planned closures would violate the plaintiffs' rights or result in situations where violation of those rights would occur.
Specifically, in regard to the ADA claims, the plaintiffs claimed that discharges or transfers from their current residences were being forced without their consent and without appropriate recommendation from treating professionals. This, they argued, violated the plaintiffs' rights under the ADA and entitled them to the relief sought. The plaintiffs claimed that their discharge or transfer from their current residence would violate the RA's integration requirement. Further, that the State utilized criteria and methods of administration that subjected the plaintiffs to discrimination based on their disability. In regards to the Medicaid claim made through the Social Security Act, the plaintiffs claimed the State failed to ensure the plaintiffs needs and preferences were being met in their multidisciplinary plan. The plaintiffs claim that the discharge process, and its lack of safeguards to prevent harm to the plaintiffs, violated plaintiffs' rights not to be deprived of life or liberty without due process of law.
On September 9, 2013, defendants moved to dismiss the complaint under Rule 12(b)(6) for failure to state a claim. The United States of America additionally filed a statement of interest arguing that plaintiffs failed to state a cause under the ADA and RA. On December 13, 2013, the District Court (Judge Stanley R. Chesler) granted the defendant's motion to dismiss. The court found that each claim either did not meet the factual standard required in pleading or that, in the case of the Medicaid claim, the cited statues did not apply to private actions.
The plaintiffs filed a notice of appeal of the order on motion to dismiss on January 10, 2014. Following appellate arguments before the Third Circuit Court of Appeals on the motion to dismiss, Circuit Court Judge Thomas M. Hardiman (joined by Circuit Judges Fisher and Jordon) entered an order determining the case to be moot. All plaintiffs at the facilities in question were transferred to alternative care facilities, making the issues presented in this case no longer live.
Summary Authors
Patrick Branson (9/24/2014)
Edward Cullen (3/15/2019)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4311240/parties/sciarrillo-v-christie/
Chesler, Stanley R. (New Jersey)
Archer, Thomas A. (Pennsylvania)
Aslan, Erin (District of Columbia)
Bohan, Mary (District of Columbia)
Cheng, Christopher N. (District of Columbia)
Aslan, Erin (District of Columbia)
Bohan, Mary (District of Columbia)
Cheng, Christopher N. (District of Columbia)
Gross, Mark L. (District of Columbia)
Handler-Menahem, Susan (New Jersey)
Hill, Eve L. (District of Columbia)
Samuels, Jocelyn (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/4311240/sciarrillo-v-christie/
Last updated April 20, 2025, 1:15 p.m.
State / Territory: New Jersey
Case Type(s):
Intellectual Disability (Facility)
Special Collection(s):
Key Dates
Filing Date: June 5, 2013
Closing Date: 2014
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Plaintiffs are all adults who are severely mentally disabled and represented by a legal guardian. Each Plaintiff was a resident at either the Woodridge Development Center in Woodbridge, NJ or the North Jersey Developmental Center in Totowa, NJ.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Denied
Defendants
New Jersey Department of Human Services, State
New Jersey Department of Human Services Division of Developmental Disabilities (Woodbridge), State
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Reassessment and care planning
Disability and Disability Rights:
Intellectual/developmental disability, unspecified
Discrimination Basis:
Disability (inc. reasonable accommodations)
Jails, Prisons, Detention Centers, and Other Institutions:
Placement in mental health facilities
Medical/Mental Health Care: