Addington v. Texas (1978)
Question: Is “beyond a reasonable doubt” the proper standard of proof for involuntary commitment to a mental health facility?
Holding: No; a “clear and convincing” standard of proof is required by the Fourteenth Amendment in a civil proceeding under state law to commit an individual to a state mental hospital involuntarily and for an indefinite period.
Lessard v. Schmidt (1972)
Question: Do patients facing involuntary civil commitment have the same procedural protections afforded to criminal defendants? What criteria warrant involuntary civil commitment?
Holding: Civil commitment should be considered a last resort when less restrictive means are insufficient. A judge may only civilly commit an individual based on evidence of mental illness and dangerousness beyond a reasonable doubt. Dangerousness is “based upon a finding of recent overt act, attempt, or threat to do substantial harm to oneself or another.” Dangerousness toward oneself was further narrowed: “Even an overt attempt to substantially harm oneself cannot be the basis for commitment unless the person is found to be 1) mentally ill, and 2) in immediate danger at the time of the hearing of doing further harm to oneself.”
O’Connor v. Donaldson (1975)
Question: Does a psychiatric hospital have the right to confine an individual in the absence of dangerous behavior, while understanding the individual continues to have a mental illness?
Holding: No; a state cannot constitutionally confine a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsibly family and friends. A finding of mental illness alone cannot justify confining such an individual.
Rennie v. Klein
Question: Does an involuntarily committed patient who has not been found incompetent have the right to refuse psychotropic mediation, barring an emergency?
Holding: Yes; due process must be followed to forcibly medicate an individual against his will, and the least restrictive alternative concept applies to medications.
Rogers v. Okin (1980)
Question: Under what circumstances would state officials be permitted forcibly administer antipsychotic medications to psychiatric patients, in accordance with due process protections?
Holding: The appellate court affirmed the right of voluntary and involuntary patients to refuse treatment. The court ruled that mental illness itself does not render a patient unable to make treatment decisions, including compliance with recommended psychiatric medication. The court expanded the definition of “emergency situation” sufficient for forcible administration of medication to include instances when medication was indicated to prevent “further suffering of that patient or the rapid worsening of his clinical condition.”
State v. Decker (2017; Decker I)
Question: Did the trial court err in subjecting an individual found incompetent and unrestorable due to a mild intellectual disability to continuing jurisdiction? That is, does a mild intellectual disability meet the criteria even when the experts opine the individual does not have a mental illness (since a moderate intellectual disability is required to be a person with an intellectual disability subject to court ordered institutionalization)?
Holding: Yes; the fact that experts found no mental illness is not dispositive. The court cited In re McKinney (1983), which stated: “If a substantial disorder of mood, thought, perception, orientation or memory grossly impairs judgment, behavior or ability to meet the ordinary demands of life, it is a ‘mental illness’ as defined by R.C. 5122.01(A), irrespective of whether the disorder is caused by mental retardation or some type of organic illness.”
State v. Jones (2017)
Question: Is a person committed for continuing jurisdiction afforded the same constitutional rights as a criminal defendant? Specifically, did the court violate the evaluee’s Sixth Amendment right to confront the witnesses?
Holding: No; The Ohio Supreme Court has stated that “Because [former] R.C. 2945 is civil in nature, a person committed under the statute need not be afforded the constitutional rights afforded to a defendant in a criminal prosecution” (State v. Williams, 2010).
Washington v. Harper (1991)
Question: What procedural requirements must be met before administering psychotropic medications to a competent, nonconsenting individual? Does the process require the presence of a judicial decision-maker?
Holding: A prisoner may be administered involuntary medication based on an administrative decision, provided he is dangerous and the medication is in his best interest. The presence of a judicial decision-maker is not necessary for determining whether involuntary medication can occur, as long as the inmate’s due process rights are preserved. The regulations for making a decision about involuntary medication met the “reasonable relation” standard; that is, the regulation was reasonably related to the state’s interest in the safety of prison staff and of the inmate. The regulation was a rational means of achieving the state’s goals, and the procedures were in line with the inmate’s due process rights (including a full, fair hearing).
Wyatt v. Stickney (1972)
Question: What standards must be met for an involuntary commitment to qualify as adequate treatment? What distinguishes treatment from a custodial placement?
Holding: Patients involuntarily committed for mental health treatment at a public psychiatric institution have the constitutional right to receive individualized treatment that will “give each of them a realistic opportunity to be cured or to improve.” The Court compared psychiatric hospitals without adequate and effective treatment to prisons where indefinite sentences are served without a criminal conviction. The Court further identified fundamental conditions for adequate and effective treatment: a humane psychological and physical environment, qualified staff in numbers sufficient to administer adequate treatment, individualized treatment plans, the right to receive adequate (but not excessive) amounts of medication, inmates could not be subjected to research without consent, and psychiatric emergencies could be declared only by qualified mental health professionals.
Youngberg v. Romeo (1982)
Question: Does the Due Process Clause grant an involuntarily committed patient the rights to safe confinement, freedom from bodily restraints, and adequate habilitation?
Holding: The involuntarily committed have liberty interests in safe confinement and freedom from bodily restraint, but a historical right to adequate habilitation was less clear. That is, no amount of habilitation would allow the respondent to live independently, and the Court was unsure what would qualify as adequate. Regarding a Professional Judgment Standard, the Court stated liability exists “only when the decision made by the professional is such a substantial departure from accepted professional judgment, practice, or standards.”