Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.
The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.
The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law
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