## Facts

- New York pursued deinstitutionalization, discharging psychiatric patients from state hospitals to community settings.
- Plaintiffs were present or former psychiatric patients who alleged either (a) discharge into homelessness in New York City or (b) continued institutionalization due to lack of suitable community placements.
- Plaintiffs alleged state and local agencies failed to provide required post-discharge services, including appropriate residential placement, supervision, and follow-up.
- Plaintiffs asserted federal and state constitutional claims and statutory claims under New York’s Mental Hygiene Law requiring discharge planning and continuity of care (including written service plans and aftercare).
- Plaintiffs sought declaratory judgments defining their rights and the agencies’ duties, and mandamus-type relief compelling officials to provide legally required services and placements.
- Trial court dismissed both class actions as nonjusticiable; the Appellate Division unanimously affirmed.
- Plaintiffs appealed to the New York Court of Appeals.

## Issues

1. Whether claims alleging failure to provide mandated post-discharge mental health services present a nonjusticiable political question due to resource allocation and administrative discretion.
2. Whether declaratory judgment is available to determine the rights of mentally ill individuals and the duties of agencies under allegedly mandatory statutes.
3. Whether mandamus-type relief may, in principle, compel compliance with specific, nondiscretionary statutory duties related to discharge planning and aftercare.

## Decision

- The Court of Appeals reversed and reinstated the complaints.
- The actions were not categorically nonjusticiable merely because compliance could be complex, discretionary in parts, or have fiscal consequences.
- Courts may issue declaratory judgments determining whether statutes impose binding duties and whether agencies have complied.
- If a statutory directive is mandatory and imposes a specific duty, courts may direct officials to proceed to perform it, while avoiding orders that displace lawful agency discretion.
- The decision did not resolve the merits of the statutory or constitutional claims; at the pleading stage, allegations were assumed true.

## Legal Principles

- Claims are justiciable when they require courts to interpret statutes and determine whether government officials have failed to perform mandatory legal duties, even if implementation implicates complex programs.
- Separation-of-powers concerns bar courts from designing or administering an entire program, but do not bar courts from declaring rights and enforcing nondiscretionary statutory obligations.
- Declaratory relief is proper to clarify legal rights and duties even when further remedial steps may later be needed.
- Mandamus (or mandamus-type relief) is available to compel performance of a clear legal duty that is nondiscretionary; courts must distinguish enforcing a duty from directing discretionary policy choices.

## Conclusion

The Court of Appeals held that suits by mentally ill individuals seeking declarations and enforcement of mandatory statutory aftercare and discharge-planning duties are fit for judicial resolution, and it reversed dismissals that treated the controversy as a nonjusticiable political question.


Klostermann v. Cuomo, 61 N.Y.2d 525 (N.Y. 1984)