O'Connor v. Donaldson 422 U.S. 563 (1975)

• Author: Kenneth L. Karst
• Pages: 1846

Page 1846

Donaldson was initially billed as the case that would decide whether a mental patient held in custody had a constitutional "right to treatment." Ultimately the Court did not decide that issue, but it did make some important pronouncements on the relation between MENTAL ILLNESS AND THE CONSTITUTION.

Kenneth Donaldson was committed to a state hospital at the request of his father; the committing judge found that he suffered from "paranoid schizophrenia." Although the commitment order specified "care, maintenance, and treatment," for almost fifteen years Donaldson received nothing but "milieu therapy"?the hospital superintendent's imaginative name for involuntary confinement. Donaldson finally sued the superintendent and others for damages under SECTION 1983, TITLE 42, UNITED STATES CODE, claiming they had intentionally denied his constitutional rights. The federal district judge instructed the jury that Donaldson's rights had been denied if the defendants had confined him against his will, knowing that he was neither dangerous nor receiving treatment. The jury awarded damages, and the court of appeals affirmed, specifically endorsing the district court's theory of a mental patient's constitutional right to treatment.

The Supreme Court unanimously held that Donaldson had stated a valid claim, but remanded the case for reconsideration of the hospital superintendent's assertion of EXECUTIVE IMMUNITY. Justice POTTER STEWART, for the Court, said that a finding of mental illness alone could not justify a state's confining a person indefinitely "in simple custodial confinement." The Court did not reach the larger question of a "right to treatment"; it disclaimed any need to decide whether persons dangerous...