Wyatt v. Aderholt

503 F.2d 1305
Brief Filed: 11/72
Court: United States Court of Appeals for the Fifth Circuit
Year of Decision: 1974

Read the full-text amicus brief (PDF, 1.4 MB)


Whether (1) mentally impaired individuals who are involuntarily confined in state institutions have the right to treatment, and (2) confinement without treatment deprives such individuals of their constitutional rights

Index Topics

Civil Commitment; Mentally Ill and Mentally Retarded (Rights of)


The original complaint alleged, inter alia, that because of prospective mass terminations of employees at Bryce Hospital — one of Alabama's two public institutions for the mentally ill — the approximately 5,000 inmates faced the bleak prospect of having no treatment. Plaintiffs requested that the court declare that patients confined to any state-operated mental health facility are constitutionally entitled to adequate, competent treatment and that defendants be enjoined from operating Bryce Hospital in a manner that does not conform to constitutional standards of delivering adequate mental treatment to the patients. On the basis of testimony elicited at the first hearing, the judge found that the treatment at Bryce Hospital was inadequate (Wyatt v. Stickney, 325 F.Supp. 781 [M.D. Ala. 1972]). The court held that patients who were involuntarily committed for treatment have a constitutional right to receive individual treatment that will give them a realistic opportunity to be cured or to improve. The hospital was given six months to improve conditions, but failed to do so. The State appealed the lower court's orders and award of attorneys' fees to the plaintiffs to the U.S. Court of Appeals for the Fifth Circuit.

APA's Position

APA submitted an amicus brief that argued: (1) recent cases have affirmed the judicial obligation of safeguarding the constitutional rights of involuntary inmates of mental institutions, including the right to adequate treatment (for example, the Supreme Court has recently held that courts have a duty to review the nature and duration of confinement of the mentally impaired who are involuntarily incarcerated; federal and state courts have recognized that mentally impaired individuals who are involuntarily confined have a right to treatment; and courts have applied constitutional standards to conditions of confinement in other institutional contexts); (2) the allegation that treatment is not provided to the mentally impaired who have been involuntarily committed presented a justiciable controversy; (3) by virtue of their confinement without treatment and under conditions of extreme deprivation, plaintiffs were deprived of liberty without due process, subjected to cruel and unusual punishment, and denied the equal protection of the laws; (4) protection of constitutional rights of inmates of state mental institutions by federal courts is consistent with the separation of powers doctrine and with maintenance of the federal system; and (5) the district court did not abuse its discretion in awarding plaintiffs reasonable attorneys' fees.


The Fifth Circuit held that the Constitution guarantees persons civilly committed to state mental institutions a right to treatment, the suit was not barred by the Eleventh Amendment, and the right to treatment could be implemented through judicially manageable standards.