United States ex rel. Best v. Barbarotta

Civil Practice

New York Law Journal


Judge Nicholas Garaufis

Characterized as delusional and paranoid, Best was found unfit for trial in state court. He was transferred to a psychiatric center, where two doctors certified him to be in need of inpatient stabilization. Alleging due process and equal protection violations, Best sought a temporary restraining order mandating release. In addition to asserting detention absent a "securing order or mandate," he claimed the trial court did not follow New York's Criminal Procedure Law when finding him unfit, and that the application for his involuntary psychiatric admission violated New York's Mental Hygiene Law. Finding each of the three requirements for application of the Younger abstention doctrine satisfied, the court denied Best's TRO motion. The state mental health proceedings are ongoing and New York has an important interest in deciding the application of its own mental health laws. Further, a TRO releasing Best—who refuses medication—into society directly implicates the state's strong interest in protecting its citizens. Noting that proceedings regarding Best's mental health originated from his criminal arrest, the court observed that the need to properly administer its criminal justice system is a "classic" state interest justifying abstention.

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