Youngberg v. Romeo

457 U.S. 307
Brief Filed: 9/81
Court: United States Supreme Court
Year of Decision: 1982

Read the full-text amicus brief (PDF, 734KB)

Issue

Whether mentally retarded residents of state hospitals have the constitutional right to be free from undue bodily restraint, the right to personal security and protection, and the right to adequate treatment

Index Topic

Mentally Ill and Mentally Retarded (Rights of)

Facts

A profoundly retarded man was involuntarily committed to a Pennsylvania state hospital. At the hospital, he was injured repeatedly and placed in restraints for long periods of time. His mother filed suit on his behalf against institutional officials claiming that the man had constitutional rights to safe conditions of confinement, freedom from bodily restraint, and habilitation (training), and that the officials knew, or should have known, that her son was suffering injuries and failed to take appropriate preventative measures, thereby violating his rights under the Eighth and Fourteenth Amendments. The trial judge gave instructions to the jury on the assumption that the Eighth Amendment applied, the jury returned a verdict for the defendants under that Amendment, and the plaintiff appealed. The Third Circuit Court of Appeals, en banc, reversed and remanded for a new trial holding that the Eighth Amendment did not apply to the facts of the case, but the Fourteenth Amendment involved liberty interests in freedom of movement and personal security which individuals involuntarily committed retained. The defendants appealed.

APA's Position

APA joined the American Orthopsychiatric Association, the Association for Retarded Citizens of the United States, the Mental Health Association,and the National Association of Social Workers as amici before the U.S. Supreme Court in support of the respondent patient. The brief argued that: (1) mental retardation is not a mental illness but a functional disorder susceptible to improvement through training and education, a) mental retardation involves slow or limited functioning accompanied by deficits in adaptive behavior, b) although they learn slowly, mentally retarded people can learn, c) without instructional programs, institutionalized mentally retarded people lose skills and often become aggressive and self-abusive, and d) with instructional programs, many if not all institutionalized mentally retarded can return to the community; (2) a non-criminal mentally retarded person confined in a Pennsylvania facility has a state statutory right to care and habilitation, which is protected against arbitrary abrogation by the Due Process Clause of the constitution; (3) even without an express statutory guarantee, a non-criminal mentally retarded person in a state facility has a right to care and habilitation directly under the Due Process Clause since care and habilitation are each constitutionally necessary purposes for commitment of mentally retarded people and, where the State has exercised its commitment power, due process requires that it provide both care and habilitation; (4) where the State has assumed custody of a non-criminal mentally retarded person for whatever reasons, it has a constitutional obligation to protect him from harm by meeting his fundamental needs, including his needs for personal security and appropriate habilitation; (5) the non-therapeutic restraint of an involuntarily institutionalized person violates his due process right to be free from punishment; and (6) the Third Circuit Court of Appeals did not err in remanding the case to the district court for resolution of the qualified immunity question.

Results

The U.S. Supreme Court vacated and remanded holding that involuntarily committed residents of state mental retardation institutions have a constitutional right to reasonably safe conditions of confinement, freedom from unreasonable bodily restraints, and the habilitation reasonably required by their protected liberty interests.