O'Connor v. Donaldson
Encyclopedia
O'Connor v. Donaldson, 422 U.S. 563
(1975), was a landmark decision
in mental health law
. The United States Supreme Court
ruled that a state cannot constitutionally confine, without more, a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsible family members or friends, and since the previous jury found, upon ample evidence, that petitioner did so confine respondent, it properly concluded that petitioner had violated respondent's right to liberty.
Kenneth Donaldson (confined patient) had been held for 15 years in Florida State Hospital
at Chattahoochee
, due to needs of "care, maintenance, and treatment". He filed a lawsuit
against the hospital and staff members claiming they had robbed him of his constitutional rights, by confining him against his will. Donaldson won his case (including monetary damages) in United States District Court
, won the appeals, and in 1975 the victory was reaffirmed by the Supreme Court.
A finding of "mental illness" alone cannot justify a State's locking a person up against their will and keeping them indefinitely in simple custodial confinement. Assuming that that term can be given a reasonably precise content and that the "mentally ill" can be identified with reasonable accuracy, there is still no constitutional basis for confining such persons involuntarily if they are dangerous to no one and can live safely in freedom.
In 1956 Donaldson traveled to Florida to visit his elderly parents. While there, Donaldson reported that he believed one of his neighbors in Philadelphia might be poisoning his food. His father, worried that his son suffered from paranoid delusions, petitioned the court for a sanity hearing. Donaldson was evaluated, diagnosed with "paranoid schizophrenia," and civilly committed to the Florida State mental health system. At his commitment trial, Donaldson did not have legal counsel present to represent his case. Once he entered the Florida hospital, Donaldson was placed with dangerous criminals, even though he had never been proved to be dangerous to himself or others. His ward was understaffed, with only one doctor (who happened to be an obstetrician) for over 1,000 male patients. There were no psychiatrists or counselors, and the only nurse on site worked in the infirmary.
He 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 half-way house
.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1975), was a landmark decision
Landmark decision
Landmark court decisions establish new precedents that establish a significant new legal principle or concept, or otherwise substantially change the interpretation of existing law...
in mental health law
Mental health law
Mental health law is the area of the law that applies to persons with a diagnosis or possible diagnosis of mental illness, and to those involved in managing or treating such people.-Mental health law in general:...
. The United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
ruled that a state cannot constitutionally confine, without more, a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsible family members or friends, and since the previous jury found, upon ample evidence, that petitioner did so confine respondent, it properly concluded that petitioner had violated respondent's right to liberty.
Kenneth Donaldson (confined patient) had been held for 15 years in Florida State Hospital
Florida State Hospital
Florida State Hospital is a hospital and mental institution in Chattahoochee, Florida. Established in 1876, it was until 1947 Florida's only state mental institution. It currently has a capacity of 1,042 patients...
at Chattahoochee
Chattahoochee, Florida
Chattahoochee is a city in Gadsden County, Florida, United States. The population was 3,287 at the 2000 census. According to the U.S Census estimates of 2005, the city had a population of 3,720. It is part of the Tallahassee, Florida Metropolitan Statistical Area.-Geography:Chattahoochee is...
, due to needs of "care, maintenance, and treatment". He filed a lawsuit
Lawsuit
A lawsuit or "suit in law" is a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint...
against the hospital and staff members claiming they had robbed him of his constitutional rights, by confining him against his will. Donaldson won his case (including monetary damages) in United States District Court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
, won the appeals, and in 1975 the victory was reaffirmed by the Supreme Court.
A finding of "mental illness" alone cannot justify a State's locking a person up against their will and keeping them indefinitely in simple custodial confinement. Assuming that that term can be given a reasonably precise content and that the "mentally ill" can be identified with reasonable accuracy, there is still no constitutional basis for confining such persons involuntarily if they are dangerous to no one and can live safely in freedom.
Kenneth Donaldson
The origins of Donaldson's institutionalization began in 1943, at age 43, when he suffered a traumatic episode. He was hospitalized and received treatment, before resuming life with his family.In 1956 Donaldson traveled to Florida to visit his elderly parents. While there, Donaldson reported that he believed one of his neighbors in Philadelphia might be poisoning his food. His father, worried that his son suffered from paranoid delusions, petitioned the court for a sanity hearing. Donaldson was evaluated, diagnosed with "paranoid schizophrenia," and civilly committed to the Florida State mental health system. At his commitment trial, Donaldson did not have legal counsel present to represent his case. Once he entered the Florida hospital, Donaldson was placed with dangerous criminals, even though he had never been proved to be dangerous to himself or others. His ward was understaffed, with only one doctor (who happened to be an obstetrician) for over 1,000 male patients. There were no psychiatrists or counselors, and the only nurse on site worked in the infirmary.
He 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 half-way house
Half-Way House
Half-Way House, also known as The Wiseburg Inn, is a historic inn and toll house located on York Road at Parkton, Baltimore County, Maryland. It is a large, -story Flemish bond brick structure. The main part, built as an inn about 1810, was placed in front of an earlier log structure which has...
.