O’Connor v. Donaldson

O'Connor v. Donaldson
422 U.S. 563 (1975) |
SCOTUS decided 1975-06-26
Jurisdiction level:

A State cannot constitutionally confine a non-dangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends.

Result: Win
Importance:

The case wa a landmark decision in mental health law. From Wikipedia: “Donaldson spent 15 years as a patient; he did not receive any treatment, actively refusing it, and attempting to secure his release. Throughout his stay he denied he was ever mentally ill, and refused to be put into a halfway house. Donaldson later wrote a book about his experience as a mental patient titled ‘Insanity Inside Out’.”


Law type: Civil
Topic(s): Fourteenth Amendment, Indefinite custodial confinement, and Mental health
State of origin: FL
Attorneys:

Bruce J. Ennis, Jr., (American Civil Liberties Union, ACLU) argued the cause for respondent. With him on the brief was Morton Birnbaum.


Others involved: Briefs of amici curiae urging affirmance were filed by E. Barrett Prettyman, Jr., for the American Psychiatric Assn.; by Francis M. Shea, Ralph J. Moore, Jr., John Townsend Rich, James F. Fitzpatrick, Kurt W. Melchior, Harry J. Rubin, Sheridan L. Neimark, and A. L. Zwerdling for the American Association on Mental Deficiency; and by June Resnick German and Alfred Berman for the Committee on Mental Hygiene of the New York State Bar Assn. William J. Brown, Attorney General, and Andrew J. Ruzicho and Barbara J. Rouse, Assistant Attorneys General, filed a brief for the State of Ohio as amicus curiae.
Organization role: Sponsor

Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
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CASE DETAILS

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)

Syllabus

Respondent, who was confined almost 15 years “for care, maintenance, and treatment” as a mental patient in a Florida state hospital, brought this action for damages under 42 U.S.C. 1983 against petitioner, the hospital’s superintendent, and other staff members, alleging that they had intentionally and maliciously deprived him of his constitutional right to liberty. The evidence showed that respondent, whose frequent requests for release had been rejected by petitioner notwithstanding undertakings by responsible persons to care for him if necessary, was dangerous neither to himself nor others, and, if mentally ill, had not received treatment. Petitioner’s principal defense was that he had acted in good faith, since state law, which he believed valid, had authorized indefinite custodial confinement of the “sick,” even if they were not treated and their release would not be harmful, and that petitioner was therefore immune from any liability for monetary damages. The jury found for respondent and awarded compensatory and punitive damages against petitioner and a codefendant. The Court of Appeals, on broad Fourteenth Amendment grounds, affirmed the District Court’s ensuing judgment entered on the verdict. Held:

1. A State cannot constitutionally confine, without more, a non-dangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends, and since the jury found, upon ample evidence, that petitioner did so confine respondent, it properly concluded that petitioner had violated respondent’s right to liberty. Pp. 573-576.

2. Since the Court of Appeals did not consider whether the trial judge erred in refusing to give an instruction requested by petitioner concerning his claimed reliance on state law as authorization for respondent’s continued confinement, and since neither court below had the benefit of this Court’s decision in Wood v. Strickland, 420 U.S. 308 , on the scope of a state official’s qualified immunity under 42 U.S.C. 1983, the case is vacated and [422 U.S. 563, 564] remanded for consideration of petitioner’s liability vel non for monetary damages for violating respondent’s constitutional right. Pp. 576-577.

493 F.2d 507, vacated and remanded.

From the opinion

MR. JUSTICE STEWART delivered the opinion of the Court.

The respondent, Kenneth Donaldson, was civilly committed to confinement as a mental patient in the Florida State Hospital at Chattahoochee in January 1957. He was kept in custody there against his will for nearly 15 years. The petitioner, Dr. J. B. O’Connor, was the hospital’s superintendent during most of this period. [422 U.S. 563, 565] Throughout his confinement Donaldson repeatedly, but unsuccessfully, demanded his release, claiming that he was dangerous to no one, that he was not mentally ill, and that, at any rate, the hospital was not providing treatment for his supposed illness. Finally, in February 1971, Donaldson brought this lawsuit under 42 U.S.C. 1983, in the United States District Court for the Northern District of Florida, alleging that O’Connor, and other members of the hospital staff named as defendants, had intentionally and maliciously deprived him of his constitutional right to liberty. 1 After a four-day trial, the jury returned a verdict assessing both compensatory and punitive damages against O’Connor and a codefendant. The Court of Appeals for the Fifth Circuit affirmed the judgment, 493 F.2d 507. We granted O’Connor’s petition for certiorari, 419 U.S. 894 , because of the important constitutional questions seemingly presented.