ALBANY, N.Y. (CN) – A man with a mental disorder who averted a rape prosecution is not entitled to keep his confinement records confidential, a New York appeals court ruled Thursday.
The 3-2 ruling out of the state court system distinguishes so-called insanity acquittees, like the individual here, from involuntarily committed civil patients.
James Q., whose full name is redacted in the court record, has been confined in a secure facility run by the Office for People with Developmental Disabilities since 2010. That year, James Q. pleaded not responsible by reason of mental disease or defect to charges for assault and third-degree rape.
The charges stemmed from a violent attack suffered by James Q.’s underage girlfriend, which also revealed his sexual relationship with her to authorities.
Though the state extended James Q.’s retention four times over the years, the case at hand erupted from a dispute over whether to seal the record of his latest retention proceedings to be sealed as part of his clinical record.
Affirming Thursday that James Q. is not entitled to a seal, Justice Christine Clark wrote for the majority that the confidentiality provisions of the state’s mental hygiene law are meant to cover individuals who have been imprisoned by the state against their will.
James Q., on the other hand, willingly submitted himself to internment when he pleaded not responsible due to mental defect.
Clark likewise found nothing to support the idea that the “Legislature intended for these proceedings – which arise only after a criminal defendant affirmatively places his or her mental competency in issue – to be sealed from the public.”
“The victim of respondent’s crimes, as well as the public at large, have a right to know how respondent is being civilly managed,” Clark added.
Writing in dissent, Justice Michael Lynch argued that James Q. is entitled to confidentiality for several reasons.
“The subject documents are protected from being made public pursuant to Mental Hygiene Law § 33.13 (c), not only due to their classification as clinical records, but also because they all identify respondent by name,” wrote Lynch, joined by Justice Sharon Aarons.
Justices John Egan and Eugene Devine concurred with the majority.