Monday, 9 December 2013

Human Rights Week 2013: Mental Capacity Bill 2013


The following post was prepared by Jillian Crowley an exchange LLB student from the USA who is studying this semester in Griffith College Dublin.  (Please note that references to disability throughout the piece refers to conditions which alter a person’s ability to make decisions)
Mental Capacity Bill 2013 

This piece focuses mainly on the Mental Capacity Bill 2013, how the provisions of the Bill will operate, how this will alter existing law, some critiques of the provisions of the Bill, and in addition some information is provided in relation to other relevant legal provisions dealing with capacity issues.

 The Mental Capacity Bill of 2013 was advanced to provide a modern framework supporting decision making for adults who have difficulty in making decisions unaided. This Bill would revise and repeal past acts as well as cause other acts to cease having effect in this area. For example the Marriage of Lunatics Act 1811 would be repealed and the Lunacy Regulation Act 1871 would cease to have effect. Other changes will also ensue; these changes consist of the replacement of wards of court system for adults, an automatic review of all those under ward ship, and an introduction of power to make legally binding agreements with supporters for assistance in decision making. The Mental Capacity Bill of 2013 seems to be a step in the right direction for those people who have difficulty making decisions on their own.

The Mental Capacity Bill of 2013 introduces three levels of Assistance. The first level is named Assisted Decision Making; this level means that individuals voluntarily appoint someone to assist with specific decisions relating to personal welfare or property and affairs. The second level is Co-decision making. Co-decision making allows the Circuit court to declare that an individual’s capacity is reduced for specific decisions but he/she would have capacity for those decisions if he/she appointed a Co-decision maker to share authority for those decisions. The final and third level of assistance is Decision Making Representatives. Decision Making Representatives operate as a form of substitute decision making for specific decisions. This level of assistance is used rarely and creates new provisions for an enduring power of attorney and informal decision making on personal welfare matters.

The Mental Capacity Bill can be considered in the context of a number of advocacy groups which have an interest in this area and who have made recommendations in relation to law reform Amongst these groups are Amnesty International, the Mental Health Reform Group, and the Centre for Disability Law and Policy. The Mental Health Reform group is set up to promote improved mental health service in Ireland and have recommended that capacity legislation provide a supported decision making stance. Another recommendation made by them was to have the term voluntary patient in mental health legislation be amended to refer solely to persons who have the capacity to consent to their admission and treatment. The second group Amnesty International recommended that the objective of the Bill be to enhance capacity and enable individuals to make decisions affecting their lives. They proposed that the Bill provide for independent capacity advocacy service and capacity advocates to guarantee that each individual receives support for any decisions made. Further they recommended that the procedure allowing for the involuntary administration of medication should stop, if a person regains capacity at any time, until that person consents to receive the medication. Thirdly, the Centre for Disability Law and Policy (CDLP) discusses legal capacity and the international shift towards a support based system which allows a person with a disability to make their own decisions. Their submission states current Irish law on legal capacity can be challenged in the European Court of Human Rights. The views of these three groups highlight the shortcomings of the bill and its compliance with the Convention on the Rights of Persons with Disabilities, and the European Convention on Human Rights. These three groups have played a major role in emphasizing the key challenges in this area, while at the same time bringing forward new ideas to improve the provisions of the Mental Capacity Bill.

The idea of capacity plays a great role in specific areas such as voting, marriage, medical decision making, and sexual relationships. Voting is the first area of capacity, any legal citizen above the age of eighteen is eligible to vote. In circumstances when a person has a disability special accommodations have been set up to facilitate this person. For example, voting at an alternative polling station if the local station is inaccessible, being helped at the polling station by a companion or presiding officer if needed, vote by post, and voting at a hospital, nursing home or similar institution if that is their principal residence. A companion voter may assist a person with intellectual disability, literacy problems, visual impairments and other physical disabilities. The companion voter may assist the individual in placing the marks on the ballot and placing the ballot within the box, but this person must not choose the candidates which this individual votes for. A person with a disability access to voting, if assistance is required, may be refused if the presiding officer establishes that this disabled person lacks the capacity to vote. Marriage is the next form of capacity where the requirements for marriages are having the capacity to marry, freely consenting to marriage, and following all necessary formalities. Consent to marriage cannot consist of any form of duress or pressure, if someone consents to marriage under a threat or intimidation then the marriage is void. Without permission from the court, both parties in a marriage must exceed the age of eighteen. A person’s capacity to marry is looked at on the understanding of the nature and effects of marriage, as well as understanding the binding nature of the contract of marriage. Wards of the Court are not permitted to marry but Wardship does not invalidate an existing marriage. Medical decisions are made only with the informed consent of a person who is being treated. Exceptions are made in emergency treatment to save a life if that person is unable to communicate or if a medical practitioner is acting under a Court order. A valid consent consists of consent not made under a threat or inducement, given when a patient was well informed and can understand, and a patient can understand the likely effects of the medical decision.  Everyone is given the presumption of capacity for medical decisions, this presumption can only be removed if there is clear evidence that the person lacks capacity, this cannot be determined solely with reference to the person having a disability. Family are not given any sort of legal rights to make decisions for any adults whether the person has a disability or not, there is no requirement for medical practitioners to follow instructions from family members, merely to consult with them. Lastly, sexual relationships between adults are lawful as long as two consenting adults over the age of seventeen or are married are engaging in these sexual relationships. The Criminal Law Sexual Offenses Act 1993 was created to specifically deal with sexual relationships regarding people with disabilities. This act makes it an offence to have or attempt to have sexual intercourse with a mentally impaired person outside the realms of marriage. Sexual acts other than intercourse are not included as criminal offences under this section. These are specific examples of rules laid down in law to deal with capacity issues which arise in defined circumstances.

            Although, the 2013 Bill is a welcome reform, its provisions are not without difficulty. Firstly, the Bill is still premised on the notion of mental capacity. Within the Bill there is no distinction between mental capacity and legal capacity. Mental capacity is defined by the decision making capacity of the person while on the other hand legal capacity focuses on the recognition of a holder of rights and an actor under the law. Historically, mental capacity or lack thereof has resulted in the removal of any legal capacity affected for people with disabilities. Yet, the tests of mental capacity within the Bill appear prima facie to be disability neutral; they do not need a diagnosis of disability as part of the assessment determining mental capacity. The assessment focuses more on people with cognitive disabilities such as psycho-social disabilities, neurological disabilities and forms of dementia to undergo tests for mental capacity. Section 3 of the bill defines “capacity” based on a functional assessment. Decisions made by a person who lacks mental capacity will lack legal force while a decision of a person who has mental capacity will be respected by the law; marriage or entering into a contract or refusing medical treatment are all examples. 

The second concern is that the Bill will substitute decision making as opposed to supported decision making. Substitute decision making entails appointing a substitute decision maker such as a power of attorney for financial decisions or a trusted relative to handle your finances. It is never a good thought to think that there may be a time in one’s life where they are no longer capable of handling certain decisions on your own, but it is always necessary for account for this unpleasant situation to occur. Therefore, choosing a person such as a trusted family member or friend that will be able to make legal, financial, or medical decisions for you according to your wishes is what substitute decision making is all about. A power of attorney is a legal document that appoints another person called the attorney to deal with your property on your behalf. A power of attorney will terminate if you become mentally incapable, to continue this power of attorney, thus if you are likely to become mentally incapable you need to make an enduring power of attorney. This legal document appoints a committee guardian or trusted adult to make decisions for someone who is not mentally capable to make his or her own decisions. Turning to Co-decision making, Co-decision makers chosen by court are only forced to agree with the person they are assisting, if a reasonable person could have made the relevant decision and no harm to the appointer or others will result from the decision. The third type of assistance, supported decision making, always operates in favor of the person with the disability who will be affected by the decisions. The individual is the decision maker and the support person explains the issues at hand and when necessary will interpret the most favorable outcome for the supported person. Even in times when the supported person is in full need of total support the individual should exercise her legal capacity to the greatest extent possible to display the wishes of the supported person. There are many different forms of supported decision making for instance those assisting a person may communicate the intentions of the individual to another in order to help him or her understand the various choices presented. They may help another recognise that a person with disabilities is also a human being with interests, wants and needs in life and is someone capable of using her or his legal capacity. The main problem with supported decision making is that there is generally no clear policy framework, at this time guardianship laws and practice still dominate all others. Difficulties emerge when designating and creating support networks when an individual is unable to identify anyone who is a trusted person or people to themselves. Also, those in institutional settings are often denied support. The main differences between substitute decisions making and supported decision making is that in the later the person being assisted is recognised as holding capacity, whereas in the former there is the use of advance commands, friends, or court appointed guardians, where the guardian has court authorized power to make decisions in the individual’s best interest according to his or her own wishes. There are laws put in place to protect against abuse of these support mechanisms.

Thirdly a major concern with the Mental Capacity Bill of 2013 is informal decision makers and the application of the Bill to other areas of law. Part seven of the Mental Capacity Bill gives legal effect to the daily decisions made by these informal decision makers to make personal decisions without formally designated assistants, co-decision makers, or decision making representatives. These decisions could be anywhere from with whom these people live with or where they reside, to how they spend their money, even decisions about the amount of support they receive during their daily activities (i.e. eating, dressing, cleaning, bathing, etc. ). This provision of the Bill will grant a wide range of power to individuals without conferring authority on them. There is no sense of supervision or monitoring the actions of the informal decision makers. The requirements of the informal decisions makers mirror those of the representative decision makers which indicate a form of guardianship or substitute decision making without any court approval or public oversight. In a way this form of informal decision making can present a serious concern for human rights.

Finally there is no specific reference to best interests within the Mental Capacity Bill. The best interests’ standard is used as the primary means for decision making while still giving weight to the wishes of the individuals. Article twelve makes no mention of the best interests and instead requires that the State “respect the rights, will, and preferences” of the individual. This is a powerful shift in the decision making assistance. In the best interests standard it is decision making from outside the will of the individual, which substitutes the decisions of the person with that of another, acting in the best interests of the person being assisted. Using the rights, will and preferences standard, the goal is shifted to develop and express long and short terms desires of the person being assisted. This ensures that people who need assistance in decision making are able to receive assistance, be respected as persons before the law and have their will and preferences realised similarly to any other person, noting of course that such personal preferences might not always be in their best interests.  The interface between the standard referred to in the Bill and the best interests of the person needs to be clarified to ensure the effective operation of the new regime. The Mental Capacity Bill will create two conceptual changes in Ireland. First Ireland will be moved from a status based approach to a functional approach and secondly the bill will emphasize the will and preference rather than best interest.

The Mental Capacity Bill of 2013 seems to be a step in the right direction for those deemed incapable of supporting themselves and with some minor changes and clarification to address the aforementioned difficulties the Bill could represent a positive change in the approach of the law to assisting persons with diminished capacity.

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