Wyatt v. Stickney

Plaintiffs, the guardians of patients confined at Bryce Hospital, Alabama (the Hospital) and certain employees of the Alabama Mental Health Board assigned to the Hospital, requested an order of reference for an authoritative determination of standards of the adequacy of the current and future mental treatment employed by the Hospital in effecting the right to treatment.

The Alabama Mental Board and the Alabama Department of Mental Health had undergone significant administrative changes. The latter was transitioning from a departmental system of organization at the Hospital to the unit-team system of delivery of mental health services and treatment to patients. The unit-team system divided the State of Alabama into “contiguous geographical county units, with mentally ill persons from each [] geographical area being assigned to a particular unit within the hospital.”

The evidence reflected that there was “considerable confusion regarding the primary mission and function of [the Hospital].”  Between 1,500 and 1,600 geriatric patients at the Hospital and approximately 1,000 mentally retarded patients were receiving custodial care only without any psychiatric treatment.

The majority of patients were involuntarily committed through noncriminal procedures and were not afforded the constitutional protections of Defendants in criminal proceedings.

Defendants, the commissioner and the deputy commissioner of the Department of Mental Health of the State of Alabama, the members of the Alabama Mental Health Board (which is responsible for the administration of all State mental health facilities and treatment centers) and others, opposed the court’s making an order of reference at that time. They argued that they should properly be allowed the opportunity to set standards and make evaluations for submission to the court prior to masters being appointed by the court to perform the task.

The case was submitted upon Plaintiff’s motion for a preliminary injunction.

The court did not grant the Plaintiff’s motion for an order of reference. However, the court upheld the right to treatment recognized in Rouse v. Cameron, 373 F.2d 451 (1967), for patients involuntarily committed through non-criminal proceedings. The court held:

There can be no legal (or moral) justification for the State of Alabama's failing to afford treatment — and adequate treatment from a medical standpoint — to the several thousand patients who have been civilly committed to [the Hospital] for treatment purposes. To deprive any citizen of his or her liberty upon the altruistic theory that the confinement is for humane therapeutic reasons and then fail to provide adequate treatment violates the very fundamentals of due process.

Nonetheless, the court could not conclude from the evidence that “the decision of the Alabama Department of Mental Health to adopt the unit-team treatment delivery approach was an improper exercise of medical and professional judgment.” Furthermore, it could not make a determination as to whether the treatment to be given under the unit-team approach was adequate because the transition had not been fully implemented at the time of the hearing upon Plaintiffs’ motion for a preliminary injunction. It was therefore concluded that it would temporarily reserve ruling upon Plaintiff’s motion.

The court requested that the Defendants, within 90 days, prepare and file with the court:

1. A precise definition of the mission and functions of the Hospital;
2. A specific plan whereby appropriate and adequate treatment will be provided to the patients at the Hospital who, from a medical standpoint, may be responsive to mental health treatment; and
3. A report reflecting in detail the progress on the implementation of the unit-team approach.

“The evidence further reflects that Alabama ranks fiftieth among all the states in the Union in per-patient expenditures per day. This Court must, and does, find from the evidence that the programs of treatment in use at Bryce Hospital prior to the reorganization that has resulted in the unit-team approach were scientifically and medically inadequate. These programs of treatment failed to conform to any known minimums established for providing treatment for the mentally ill.” 325 F.Supp., p. 784.

“The patients at Bryce Hospital, for the most part, were involuntarily committed through noncriminal procedures and without the constitutional protections that are afforded defendants in criminal proceedings. When patients are so committed for treatment purposes they unquestionably have a constitutional right 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 . . . Adequate and effective treatment is constitutionally required because, absent treatment, the hospital is transformed ‘into a penitentiary where one could be held indefinitely for no convicted offense.’ []. The purpose of involuntary hospitalization for treatment purposes is treatment and not mere custodial care or punishment. This is the only justification, from a constitutional standpoint, that allows civil commitments to mental institutions such as Bryce.” 325 F.Supp., p. 784.

“According to the evidence in this case, the failure of Bryce Hospital to supply adequate treatment is due to a lack of operating funds. The failure to provide suitable and adequate treatment to the mentally ill cannot be justified by lack of staff or facilities.” 325 F.Supp., p. 784.

“There can be no legal (or moral) justification for the State of Alabama's failing to afford treatment — and adequate treatment from a medical standpoint — to the several thousand patients who have been civilly committed to [the Hospital] for treatment purposes. To deprive any citizen of his or her liberty upon the altruistic theory that the confinement is for humane therapeutic reasons and then fail to provide adequate treatment violates the very fundamentals of due process.” 325 F.Supp., p. 785.

“A failure on the part of the defendants to implement fully, within six months from the date of this order, a treatment program so as to give each of the treatable patients committed to Bryce facility a realistic opportunity to be cured or to improve his or her mental condition, will necessitate this Court's appointing a panel of experts in the area of mental health to determine what objective and subjective hospital standards will be required to furnish adequate treatment to the treatable mentally ill in the Bryce facility. This will include an order requiring a full inspection of the existing facilities, a study of the operational and treatment practices and programs, and recommendations that will enable this Court to determine what will be necessary in order to render the Bryce facilities a mental health unit providing adequate and effective treatment, in a constitutional sense, for the patients who have been involuntarily committed and are confined there.” 325 F.Supp., p. 785.