Page last updated: 07/24/06
Patrick v. State, 11 Misc. 2d 296, 806 NYS 2nd 849 (Dec 5. 2005 NY Ct of Claims) ( wrongful death action - case reflects emerging professional standards in restraint and seclusion prevention, training and utilization)
Autism Society of Michigan and Michigan Protection and Advocacy Services, Inc. v. Fuller, No 5:05-CV-73, 2006 WL 1519966 (W.D. Mich. May 26, 2006) (plaintiffs sought declaratory and injunctive relief for purpose of getting school officials to establish seclusion and restraint policies and to train staff - dismissed for lack of standing)