LANDMARK CASES IN FORENSIC PSYCHIATRY:
Prisoners’ Rights
Baxstrom v. Herold, 1966
Case Summary:
Baxstrom was a prisoner nearing the end of his sentence at a DOC state hospital after being certified “insane.”
Prior to release, civil commitment was pursued. transfer to a civil facility was recommended, but Baxstrom was retained in the DOC facility.
Baxstrom filed habeas corpus, arguing that his retention in the DOC facility violated the Equal Protection Clause of the 14th Amendment, and that if he was insane, he should be transferred to a civil facility.
The US Supreme Court ruled in favor of Baxstrom, finding NY’s procedures for civil commitment of prisoners violated Equal Protection, treating prisoners differently than non-prisoners.
Civil commitment procedures require a full jury trial to determine mental illness, which Baxstrom wasn't granted.
Commitment to a DOC facility requires a finding of dangerousness too great for a civil facility.
Key Concepts:
Under the Equal Protection Clause of the 14th Amendment, prisoners facing civil commitment following incarceration have the right to a jury trial to determine presence of mental illness.
Estelle v. Gamble, 1976
Case Summary:
While incarcerated, Gamble suffered a back injury. He requested medical treatment, but received what he believed to be delayed and inadequate care.
Gamble argued he did not receive a proper diagnosis or treament, leading to a worsening of his condition. He sued the prison, arguing violation of 8th Amendment protection from Cruel & Unusual Punishment.
US Supreme Court ruled that prisoners have a right to protection from “deliberate indifference” to serious medical needs, as their confinement prevents them from seeking care independently.
Key Concepts:
Under the 8th Amendment, prisoners have a constitutional right to protection from “deliberate indifference” to serious medical needs..
“Deliberate Indifference” Standard: the conscious, intentional disregard of a prisoner’s serious medical needs
Vitek v. Jones, 1980
Case Summary:
Vitek was diagnosed with a mental health condition and involuntary transferred from prison to a psychiatric hospital for treatment. He argued this transfer violated the Due Process Clause of the 14th Amendment as he did not receive a hearing.
US Supreme Court ruled that involuntary transfer from prison to a psychiatric hospital requires due process protections.
Key Concepts:
Prior to involuntary transfer from prison to a psychiatric hospital, prisoners have a right to Due Process protections, including: (Vitek v. Jones, 1980)
Notice
Legal counsel
Adversarial hearing with an independent decision maker & opportunity to present evidence and testimony
Farmer v. Brennan, 1994
Case Summary:
Farmer, a transgender woman, was incarcerated in general population at a male federal prison, where she was subject to sexual assault and violence.
She argued violation of 8th Amendment protection from Cruel & Unusual Punishment, alleging deliberate indifference to her safety by prison officials.
US Supreme Court ruled in favor of Farmer, finding that the “deliberate indifference” standard is met if prison officials have actual knowledge of a specific risk of harm (subjective awareness), which they fail to acknowledge and take reasonable steps to abate.
Negligence is insufficient; requires recklessness (conscious disregard).
Key Concepts:
Under the 8th Amendment right to protection from Cruel & Unusual Punishment, prisoners have a right to protection from deliberate indifference, for which the standard is subjective awareness.
Actual knowledge of a specific risk of harm, with failure to acknowledge and take reasonable steps to abate.
Brown v. Plata, 2011
Case Summary:
California prisons were over capacity, leading to severe overcrowding, inadequate healthcare & staffing, and unsafe conditions.
Two class action suits involving prisoners with serious medical and mental health conditions argued violation of 8th Amendment right to protection from Cruel & Unusual Punishment based on prison conditions.
A district court panel found the prison conditions unconstitutional as they did not meet minimum standards according to Prison Litigation Reform Act (PLRA), ordering a reduction in capacity.
US Supreme Court affirmed need for reduction in capacity.
Key Concepts:
Significant overcrowding in California prisons led to constitutional violations, including inability to provide adequate medical and psychiatric care, requiring a reduction in prison capacity.