## Facts

- Lyle R. Goetz, an indigent involuntary patient at Harlem Valley Psychiatric Center in Dutchess County, New York, brought a class action on behalf of similarly situated patients facing involuntary commitment or retention.
- New York’s civil-commitment framework required psychiatric testimony supporting commitment or retention and allowed a court to appoint an “independent psychiatrist” to examine the patient and testify regarding the patient’s mental condition.
- Goetz asserted a due process right to a state-provided “consulting psychiatrist” for indigent patients in every commitment/retention proceeding to (a) assist counsel’s case preparation and (b) testify for the patient when clinically warranted.
- Goetz also challenged, as applied in Dutchess County, the functioning of the statutory mechanism for appointing an independent psychiatrist, alleging infrequent use, limited expert availability, delays, and compensation levels that deterred participation.
- The district court granted summary judgment for defendants on the due process challenges to New York’s procedures, rejecting the asserted constitutional entitlement to the requested psychiatric assistance.

## Issues

1. Whether the Fourteenth Amendment Due Process Clause requires the state to provide indigent persons subject to involuntary commitment or retention with a consulting psychiatrist in every proceeding to assist counsel and potentially testify for the patient.
2. Whether New York’s procedures for appointing an independent psychiatrist are constitutionally sufficient as applied in Dutchess County in light of alleged rarity of appointment, limited availability, delay, and inadequate compensation.

## Decision

- The Second Circuit affirmed the judgment insofar as it rejected a categorical due process right to a consulting psychiatrist in every commitment or retention proceeding.
- The court held that the Due Process Clause does not confer an absolute right to state-funded psychiatric assistance in the form requested.
- The court remanded for further proceedings on the as-applied challenge to the adequacy of Dutchess County’s operation of the independent-psychiatrist appointment procedure, concluding that factual disputes required development.
- The court stated that, although no per se entitlement exists, circumstances may arise in which participation by a psychiatrist unassociated with the state is constitutionally required.

## Legal Principles

- Involuntary civil commitment implicates a substantial liberty interest and triggers due process protections evaluated through a balancing of private interests, risk of error and value of additional safeguards, and governmental fiscal/administrative burdens.
- Due process does not require a blanket rule that the state fund a consulting psychiatrist for every indigent respondent in commitment or retention proceedings.
- Due process may require appointment of a psychiatrist unassociated with the state in particular cases, depending on factors such as the complexity and contestability of psychiatric questions and the risk of erroneous deprivation under existing procedures.
- An as-applied due process claim may proceed where the statutory safeguard (discretionary appointment of an independent psychiatrist) is alleged to be ineffective in practice due to systemic delay, scarcity of available experts, or conditions that deter appointments.

## Conclusion

The court rejected a categorical constitutional entitlement to a state-funded consulting psychiatrist for indigent patients in all civil-commitment proceedings, but remanded for fact-finding on whether the independent-expert appointment process, as implemented in Dutchess County, provided sufficient due process protections in practice.


Goetz v. Crosson, 967 F.2d 29 (2d Cir. 1992)