Can "district court" opinions be used in other states?

[Andromeda424]

Jurisdiction

New Jersey

Sorry if it's a nonsensical question (Please advise me if this is the case).

Basically, I'm reading in law books about this ruling:
720 F.2d 266 (1983)
John E. RENNIE
v.
Ann KLEIN


It says "The district court recognized a constitutional right to refuse treatment. Rennie v. Klein, 462 F.Supp. 1131 (D.N.J.1978) and 476 F.Supp. 1294 (D.N.J.1979)."

Now, this does say "constitutional right", so does this mean that such a right would apply in Michigan?
The book, calle "Landmark cases in Forensic Psychiatry", says "This case represents a treatment-driven approach to establishing a patient's right to refuse treatment", suggesting that there are alternative routes that are to be taken upon refusal of the medication.

However, based on this case the book doesn't say this means all patients in America have a right to refuse, it specifies that yes, civilly committed patients in NJ have this right based on the case. So can I use this in a court hearing in Michigan to justify refusing a blood draw in a non-emergent situation?

 

[Zigner]

Please keep your related (big-picture related) questions in your original thread: What does a petition for a writ of habeas corpus look like for psychiatric holds?

 

[adjusterjack]

Please keep your related (big-picture related) questions in your original thread: What does a petition for a writ of habeas corpus look like for psychiatric holds?

As much as I dislike multiple threads on the same topic I think a specific question was properly answered in the other thread, which I've closed to avoid parallel discussions. I'll leave this alone for a while.

 

[Zigner]

As much as I dislike multiple threads on the same topic I think a specific question was properly answered in the other thread, which I've closed to avoid parallel discussions. I'll leave this alone for a while.

Fair enough

 

[PayrollHRGuy]

The OP set is Jurisdiction in this post to NJ. It was MI in the other post.

 

[Zigner]

The OP set is Jurisdiction in this post to NJ. It was MI in the other post.

Interesting...

 

[adjusterjack]

Sorry if it's a nonsensical question

It's actually not. But it's vague. And before I address it I ask to you please keep ALL of your future questions about law in THIS thread so we don't have to keep jumping around to figure out what is happening.

It would also help to know the details of what gave rise to your questions. For example if you were placed on a psychiatric hold against your will and blood was drawn, tell us what the situation was and then we can address the law regarding the situation. Otherwise you just waste our time if we have to draw information out of you piece by piece.

Now, to the question in the title of this thread.

Can "district court" opinions be used in other states?

Theoretically, I suppose they can, if they can be found and cited. Only appellate decisions are reported in a way that they can be searched by topic. But even they are not precedential or binding on other states though they can often be persuasive. You also have to know how to read them and put the entire decision in context.

Rennie v. Klein is a decision from the US Court of Appeals (federal court) which is more likely (but not required) to rely on multi-state lower court decisions than state courts are.

The "district" courts cited are federal district courts, not state courts. Any federal appellate decision could very well be persuasive in states other than NJ, but not always so.

Instead of reading a book about Rennie v. Klein, read the decision and read the cited cases (there are links to them).

RENNIE v. KLEIN | 720 F.2d 266 (1983) | 0f2d2661954 | Leagle.com

And then tell us what happened to you so we can speak intelligently on the subject.

 

[adjusterjack]

The OP set is Jurisdiction in this post to NJ. It was MI in the other post.

I think he's in MI wanting to know if NJ cases are precedential in MI. I covered part of it but more details about his situation are wanting.

 

[Tax Counsel]

So can I use this in a court hearing in Michigan to justify refusing a blood draw in a non-emergent situation?

The case you cited was a decision of the U.S. Court of Appeals for the Third Circuit, a court that determines the federal law that applies in PA, NJ, and DE. It is not binding on federal or state courts outside of those three states. In that situation, you could use the case for its persuasive value if there are no U.S. Supreme Court cases, cases from the U.S. Court of Appeals for the Sixth Circuit (which is the federal court that covers Michigan) or Michigan state court cases that address the issue as the decisions of those courts would determine the law that applies in Michigan. If there are any cases from those courts, those are the ones you need as those are the decisions the Michigan state courts must follow.

 

[zddoodah]

It says "The district court recognized a constitutional right to refuse treatment. Rennie v. Klein, 462 F.Supp. 1131 (D.N.J.1978) and 476 F.Supp. 1294 (D.N.J.1979)."

The quoted language appears nowhere in the cited district court opinion, but it does appear in the cited appellate opinion.

The cited opinions are decisions made nearly or over 40 years ago by federal district and appellate courts. I didn't read either opinion thoroughly, but they involved an individual who had been involuntarily committed at a state psychiatric hospital a dozen times over less than a decade. In the district court's opinion, the judge cited a U.S. Supreme Court decision (Jacobson v. Massachusetts, 197 U.S. 11 (1905)) for the proposition that "[t]he constitutional right to refuse treatment cannot be absolute." He also noted that, while plaintiff might have such a right, "the other patients in the hospital also have a constitutional right to protection from harm."

While it is certainly correct that both courts "recognized [that] a constitutional right to refuse [medical] treatment" exists, they also recognized that such right is not absolute.

Now, this does say "constitutional right", so does this mean that such a right would apply in Michigan?

All constitutional rights apply everywhere in the United States.

The book, calle "Landmark cases in Forensic Psychiatry", says "This case represents a treatment-driven approach to establishing a patient's right to refuse treatment", suggesting that there are alternative routes that are to be taken upon refusal of the medication.

I'm not sure what that quote means without having any context, and I doubt anyone here has any expertise with treatment with persons who have been involuntarily committed to psychiatric hospitals.

However, based on this case the book doesn't say this means all patients in America have a right to refuse, it specifies that yes, civilly committed patients in NJ have this right based on the case.

This sentence is quite garbled, but it is not correct to say that "civilly committed patients in NJ have this right based on the case." The underlying constitutional right has apparently existed at least since 1905. I have no idea when it might have been first applied to persons such as the plaintiff in Rennie.

So can I use this in a court hearing in Michigan to justify refusing a blood draw in a non-emergent situation?

Non-emergent or non-emergency? In any event, here's what you need to know about case authority:

Court opinions are segregated into two categories: binding and persuasive. Binding authority is authority that must be followed by other courts. For example, decisions of the United States Supreme Court regarding issues of federal law must be followed by all other courts in the U.S. Decisions of the Florida Supreme Court regarding issues of Florida law must be followed by all other courts in Florida. Decisions of a Florida appellate court regarding issues of Florida law must be followed by all Florida trial courts.

By contrast, decisions by trial-level courts (i.e., the courts where most cases are initially filed), including United States District Courts are not binding on any other court. Such opinions, however, may be persuasive to other courts. Similarly, decisions by federal appellate courts, while binding on lower level federal courts in their circuits, are not binding on state courts or federal courts in other circuits. As to matters of federal law, only opinions of the U.S. Supreme Court are binding on state courts. In other words, while no court in Michigan is obligated to following the holdings in the Rennie cases, a judge in Michigan might find the reasoning of that opinion to be persuasive.

Thus, you can "use" (i.e., cite) the Rennie opinions in a brief filed in a Michigan state or federal court, but the judge would be completely free to ignore them and rule in a completely contrary way. Based on your brief description of your case, it does not sound like the facts in the Rennie case are even remotely similar, so I doubt it would have any persuasive value.

Only appellate decisions are reported in a way that they can be searched by topic.

That's not correct. Nowadays, all (or nearly all) federal district court opinions are "published" in a way that they can be accessed via services like Lexis, Westlaw, etc. (and, before the advent of electronic legal research services, researched via Shepard's Citations). Back in the late-70s (when the opinion the OP asked about was issued), publication of district court opinions was far less common, but many (including Rennie) were published. As the citation the OP provided indicates, the Rennie decision was published in a case reporter called West's Federal Supplement (which has been publishing district court and other lower federal court opinions since the 1930s). There is (or was) another reporter called Federal Rules Decisions that published