Federal courts must give a state court decision the same preclusive effect that it would receive in state court.

—holding that an "expressed intent to provide assistance," without an "affirmative act of restraining the individual's freedom to act," did not create a special relationship between state guardians and mentally-handicapped adults placed in residential care

In New York, `once a claim is brought to a final conclusion, all other claims arising out of the same transaction or series of transactions are barred, even if based upon different theories or if seeking a different remedy

To obtain a preliminary injunction, a party must "demonstrate [](1) irreparable harm and (2) either (a) likelihood of success on the merits or (b) `sufficiently serious questions' on the merits and a balance of hardships `tipping decidedly'in the movant's favor. "

—even though the plaintiffs' commitment to out-of-state residential treatment facilities did not give rise to Youngberg rights, an "involuntary transfer" to in-state facilities would "restrict plaintiffs' liberty" and thereby "implicate the Due Process Clause."

Mere custody, however, will not support a "special relationship" claim where a "person voluntarily resides in a state facility under its custodial rules."

—holding there was no "duty to exercise professional judgment" because the plaintiffs were not under a "state-imposed restraint" (internal quotation marks omitted

Courts generally agree that individuals who voluntarily admit themselves to a state-run mental health facility do not have substantive due process rights simply because they are in the state's custody.

It further asserts that every published circuit court decision to consider this matter post-DeShaney has determined that involuntary confinement is required to implicate residents' Youngberg rights.

This Court agreed with the First, Second, Third, Fifth, and Ninth Circuits that the involuntary nature of the commitment determines whether the State has a constitutional duty of care. See Op. at 12-18