Brown v. Smith

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division MELISSA BROWN, ) Plaintiff, v. 1:24-cv-477 (LMB/IDD) NELSON SMITH, in his official capacity as Commissioner of the Virginia Department of _) Behavioral Health and Developmental ) Services, ) Defendant. MEMORANDUM OPINION Plaintiff Melissa Brown (“plaintiff or “Brown’) brings an as-applied challenge to Virginia’s “barrier statute,” Va. Code § 37.2-416.1, alleging that the statute violates the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the United States Constitution by…