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Alabama Department of Mental Health & Mental Retardation v. Ammons
Citation: 492 So. 2d 613Docket: Civ. 5076
Court: Court of Civil Appeals of Alabama; March 25, 1986; Alabama; State Appellate Court
An appeal has been filed by the Alabama Department of Mental Health and Mental Retardation regarding the commitment of seven-year-old Daniel Corey Ammons to its custody, as ordered by the District Court of Houston County, Juvenile Division. Daniel is diagnosed with 4-P Trisomy, resulting in profound mental retardation, along with multiple medical issues including a congenital heart defect, orthopedic problems, and respiratory difficulties. Following professional advice, Daniel's parents petitioned for his commitment in April 1985, which was duly notified to Mental Health. Mental Health contended it lacked suitable facilities for Daniel and that his acceptance would lead to overcrowding. However, the juvenile court ruled that the J.S. Tarwater facility was adequate for Daniel's needs and would not cause overcrowding. Mental Health does not dispute Daniel's severe mental condition or the potential risk he poses if left in the community. The central legal issue revolves around whether the juvenile court can commit a child when adequate facilities are claimed to be unavailable. The presiding opinion emphasizes that before this issue can be addressed, it must be established that no adequate and uncrowded facility exists. The court found that the juvenile court's determination regarding the adequacy of the facility and overcrowding was supported by the evidence presented. Testimony from Mental Health's witnesses was inconclusive, mainly suggesting that Daniel's severe medical needs were the basis for their claims of inadequacy. Dr. Latham confirmed that the Tarwater Development Center could adequately provide the necessary habilitation training for Daniel, indicating it would be the correct placement if not for his medical issues. Mrs. Maddox expressed concern over Daniel's need for 'skilled nursing care,' but this concern was not supported by the testimonies of Dr. Stanley Forston, Jr., Daniel's pediatrician, or Dr. Mracek. Although Dr. Mracek initially claimed that Daniel required skilled nursing care, he later conceded that Daniel's only significant need was close observation for potential medical issues, which could be managed at home if not for his mental retardation. He acknowledged that Daniel's mother had successfully provided this care in the past despite lacking formal medical training. Dr. Forston testified that while Daniel has severe medical issues, they have stabilized and require only routine medical care, not continuous skilled nursing. He noted that if not for Daniel's mental and behavioral challenges, his mother could meet his medical observation needs. Given the expert testimonies supporting that Daniel's primary medical requirement is observation and that this need was being met at Tarwater, the juvenile court's decision to place Daniel there was not deemed erroneous. Additionally, there was insufficient evidence to support claims from Mental Health that Daniel's admission would lead to overcrowding at Tarwater; testimonies indicated that the facility's staff was adequately managing the needs of all residents, including Daniel, without neglect. Mental Health's argument hinged on Daniel needing skilled nursing care and the lack of a habilitation program for children under eight, but the facility had previously managed to create additional capacity as needed. The juvenile court's ruling was affirmed based on the evidence presented.