LANDMARK CASES IN FORENSIC PSYCHIATRY:

Right to Treatment

Rouse was found NGRI on a misdemeanor weapon charge with a max sentence of 1 year, and committed to St. Elizabeth’s Hospital.
He petitioned Cameron, the superintendent, for release, claiming that he had received no psychiatric treatment over the past 3 years. Habeas corpus was denied.
On appeal, the court ruled that the statutory right to treatment is applicable to NGRI acquittees.

NGRI acquittees have a right to treatment
The purpose of involuntary commitment is treatment, not punishment
- Without treatment, “the hospital is transformed into a penitentiary where one could be held indefinitely for no convicted offense”

Wyatt, a patient at Alabama’s Bryce Hospital, sued Stickney, the Commissioner of Mental Health, over poor hospital conditions and treatment.
The Alabama District Court found the hospital conditions grossly deficient, and failed to improve after given 6 months to do so.
Formal hearings were held to determine minimum constitutional psychiatric treatment standards, which were later extended to institutions for those with intellectual disabilities.

Civilly committed patients have a constitutional right to minimally adequate standards for psychiatric treatment:
”To receive such individual treatment as will give each of them a realistic opportunity to be cured or to improve his or her mental condition.”
Minimum standards may include a humane psychological and physical environment, qualified staff, adequate staffing ratios, and individualized treatment plans.
Confining patients without treatment violates Due Process (14th Amendment)

Romeo was a man with severe intellectual impairments who was committed to Pennhurst, a state institution.
Romeo’s mother sued Youngberg, the superintendent, for 8th Amendment violations due to concerns about injuries and failures to take preventive measures.
The Supreme Court ruled that institutionalized individuals are dependent on the state and have protected liberty interests under the Due Process clause of the 14th Amendment.
The issue was whether Pennhurst had met the standard of care.

Institutionalized individuals have protected liberty interests, including safe conditions, freedom from physical restraint, and minimally adequate habilitation to reduce the need for restraint.
The Due Process clause of the 14th Amendment, not the 8th, provides the constitutional basis.
The standard for determining whether the state met its duty is professional judgment.