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 On March 26, 2024, plaintiff Melissa Brown (“plaintiff’ or “Brown’”) filed an as-applied challenge to Va. Code § 37.2-416.1, alleging that the statute violates the Equal Protection, Due Process, and Privileges or Immunities Clauses of the Fourteenth Amendment to the Constitution by…