Washington v. Harper
Encyclopedia
Washington v. Harper 494 U.S. 210
(1990) is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic
medication.
Upon his second hospitalization at the Center, Harper filed suit in state court under 42 U.S.C. 1983, alleging that the Center failed to provide a judicial hearing before involuntarily medicating him, thus violating the due process
clause of the Fourteenth Amendment
. The trial court rejected his claim but the State Supreme Court reversed the decision and remanded the case back to the trial court stating that the State could administer antipsychotic medication to a competent, nonconsenting inmate only if, in a judicial hearing, at which the inmate had full adversarial procedural protections, the State could proved by "clear, cogent, and [494 U.S. 210, 211] convincing" evidence that the forced medication was necessary and effective for furthering an important state interest, weighing the individuals interest against that of the state.
The United States Supreme Court granted a Writ of Certiorari.
The American Psychological Association
submitted an amicus
brief in support of the inmate's right to a due process hearing, stating forced medication of an incarcerated inmate violated the due process
, equal protection, and free speech clauses of the Constitution of the United States.
The United States Supreme court ruled that the Due Process Clause permits a state to treat an incarcerated inmate having a serious mental disorder with antipsychotic medication against his will, under the condition that he is dangerous to himself or others and the medication prescribed is in his best medical interest.
Six members of the Court disagreed with Harper's argument that he had a right to due process through the court. In this decision the United States Supreme Court weighs in on the side that it is preferable for medical professionals to make treatment decisions rather than have those decisions made through judicial proceedings.
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...
(1990) is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic
Antipsychotic
An antipsychotic is a tranquilizing psychiatric medication primarily used to manage psychosis , particularly in schizophrenia and bipolar disorder. A first generation of antipsychotics, known as typical antipsychotics, was discovered in the 1950s...
medication.
Circumstances
Respondent Harper, an inmate in the Washington prison system since 1976, had a history of becoming violent when not on antipsychotic medication. Twice he was transferred to the Special Offender Center (SOC), a state institution for convicted offenders with serious psychiatric problems. While there, Harper was forced to take psychiatric medication against his will. The SOC followed its policies of institutional review for making a treatment decision to forcibly medicate an inmate.Upon his second hospitalization at the Center, Harper filed suit in state court under 42 U.S.C. 1983, alleging that the Center failed to provide a judicial hearing before involuntarily medicating him, thus violating the due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
clause of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. The trial court rejected his claim but the State Supreme Court reversed the decision and remanded the case back to the trial court stating that the State could administer antipsychotic medication to a competent, nonconsenting inmate only if, in a judicial hearing, at which the inmate had full adversarial procedural protections, the State could proved by "clear, cogent, and [494 U.S. 210, 211] convincing" evidence that the forced medication was necessary and effective for furthering an important state interest, weighing the individuals interest against that of the state.
The United States Supreme Court granted a Writ of Certiorari.
The American Psychological Association
American Psychological Association
The American Psychological Association is the largest scientific and professional organization of psychologists in the United States. It is the world's largest association of psychologists with around 154,000 members including scientists, educators, clinicians, consultants and students. The APA...
submitted an amicus
Amicus
Amicus was the United Kingdom's second-largest trade union, and the largest private sector union, formed by the merger of Manufacturing Science and Finance, the AEEU agreed in 2001, and two smaller unions, UNIFI and the GPMU...
brief in support of the inmate's right to a due process hearing, stating forced medication of an incarcerated inmate violated the due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
, equal protection, and free speech clauses of the Constitution of the United States.
Decision
The US Supreme Court reversed, finding the use of an internal institutional review was adequate in making treatment decisions in this case under the lesser standard of review embodied in Turner v. Safely, .The United States Supreme court ruled that the Due Process Clause permits a state to treat an incarcerated inmate having a serious mental disorder with antipsychotic medication against his will, under the condition that he is dangerous to himself or others and the medication prescribed is in his best medical interest.
Significance
At issue in this case was the institutional policy of forming a treatment decision team made up of two mental health professionals and one associate superintendent. This three person committee evaluated issues such as the severity of the inmate's mental disorder and the risk to himself or others and then made the treatment decision.Six members of the Court disagreed with Harper's argument that he had a right to due process through the court. In this decision the United States Supreme Court weighs in on the side that it is preferable for medical professionals to make treatment decisions rather than have those decisions made through judicial proceedings.
See also
- List of United States Supreme Court cases, volume 494
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Riggins v. NevadaRiggins v. NevadaRiggins v. Nevada, is a U.S. Supreme Court case in which the court decided whether a mentally ill person can be forced to take antipsychotic medication while they are on trial to allow the state to make sure they remain competent during the trial....
,