O’Connor v. Donaldson

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O’CONNOR v. DONALDSON
No. 74-8
SUPREME COURT OF THE UNITED STATES
422 U.S. 563; 95 S. Ct. 2486; 45 L. Ed. 2d 396; 1975 U.S.
Argued January 15, 1975
June 26, 1975

PRIOR HISTORY: CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

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SUMMARY: A former patient of a state mental hospital, who throughout his nearly 15 years of confinement in the hospital had repeatedly demanded his release, claiming that he was dangerous to no one, that he was not mentally ill, and that the hospital was not providing treatment for his supposed illness, brought an action under 42 USCS 1983, in the United States District Court for the Northern District of Florida, alleging that the hospital superintendent and other members of the hospital staff had intentionally and maliciously deprived him of his constitutional right to liberty. The testimony at trial demonstrated that the former patient posed no danger to others or to himself during the time he had been confined, and also showed that his requests for release had been supported by responsible persons willing to provide any care he might need on release. The superintendent’s principal defense was that he had acted in good faith and was therefore immune from any liability for monetary damages. Although rejecting a proposed instruction reflecting the superintendent’s contention, the District Court did instruct the jury that monetary damages could not be assessed against the superintendent if he had believed reasonably and in good faith that the patient’s continued confinement was proper, and that punitive damages could be awarded only if the superintendent had acted maliciously or wantonly or oppressively. The jury returned a verdict assessing both compensatory and punitive damages against the superintendent and a codefendant, and the Court of Appeals for the Fifth Circuit affirmed (493 F2d 507).

On certiorari the United States Supreme Court vacated the judgment of the Court of Appeals and remanded the case. In an opinion by Stewart, J., expressing the unanimous view of the court, it was held that (1) a state cannot constitutionally confine in a mental hospital, without more, a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends and (2) the Court of Appeals must consider, in light of an intervening Supreme Court decision on the scope of the qualified immunity possessed by state officials under 42 USCS 1983, whether the District Judge’s failure to instruct with regard to the effect of the superintendent’s claimed reliance on state law rendered inadequate the instructions as to the superintendent’s liability for compensatory and punitive damages.

Burger, Ch. J., concurring, also expressed the views that (1) the former patient’s refusal of treatment should be taken into account in considering the superintendent’s good-faith defense, (2) the numerous denials, in state court proceedings, of the former patient’s requests for release should be considered on the issue of immunity, and (3) the Supreme Court’s opinion gives no approval to the Court of Appeals holding that a person who is involuntarily committed to a mental hospital has a constitutional right to receive such treatment as will give him a realistic opportunity to be cured.

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