O’Connor v. Donaldson

Respondent, Donaldson, was civilly committed to confinement as a mental patient in the Florida State Hospital in 1957; he was kept in custody against his will for nearly 15 years. Petitioner, O’Connor, the hospital’s superintendent, had repeatedly refused Donaldson’s requests to be released. Donaldson’s requests for ground privileges, occupational training, and an opportunity to discuss his case with O’Connor or other staff members were repeatedly denied.

Trial evidence indicated that Donaldson’s confinement “was a simple regime of enforced custodial care, not a program designed to alleviate or cure his supposed illness.” Evidence also indicated that the hospital staff possessed the ability to recognize when a patient was not dangerous to himself or others, even if he remained mentally ill and had been lawfully committed. Trial evidence also demonstrated that Donaldson had not posed any danger to others either during his period of confinement or at any point in his life. In addition, there was no evidence that respondent had ever been suicidal or thought likely to inflict injury upon himself. Moreover, there was some evidence to suggest that Donaldson could have earned his own living outside the hospital, and his requests for release had been supported by responsible persons willing to provide any care needed.

Respondent brought a claim in 1971 alleging that O’Connor and other members of the hospital had “intentionally and maliciously deprived him of his constitutional right to liberty.” The Court of Appeals affirmed the trial verdict, which assessed both compensatory and punitive damages against O’Connor and a codefendant. The Court of Appeals addressed “the far-reaching question whether the Fourteenth Amendment guaranteed a right to treatment to persons involuntarily committed to state mental hospitals.” It held that when a patient was confined based on the need for treatment the Constitution required that “minimally adequate treatment in fact be provided.” The Court of Appeals held:

[R]egardless of the grounds for involuntary civil commitment, a person confined against his will at a state mental institution [had] a constitutional right to receive such individual treatment as [would] give him a reasonable opportunity to be cured or to improve his mental condition.

The Supreme Court declared that there was “no reason to decide whether mentally ill persons dangerous to themselves or to others [had] a right to treatment upon compulsory confinement by the State, or whether the State [could] compulsorily confine a nondangerous, mentally ill individual for the purpose of treatment.” Rather the Court stated that the case involved “a single, relatively simple, but nonetheless important question concerning every man’s constitutional right to liberty.”

The Court examined whether the State could constitutionally confine a nondangerous person who was capable of surviving safely in freedom (independently or with the help of family and friends). The Court held that, since the jury found that O’Connor, as an agent of the State, knowingly confined Donaldson, his constitutional right to freedom had been violated. The Court held that “a finding of mental illness alone cannot justify a State's locking a person up against his will and keeping him indefinitely in simple custodial confinement.” It held that there was “no constitutional basis for confining such persons involuntarily if they [were] dangerous to no one and [could] live safely in freedom.”

The Court further held that while the State has a proper interest in providing care and assistance to the unfortunate, the mere presence of mental illness “does not disqualify a person from preferring his home to the comforts of an institution.” A more superior living standard to that enjoyed in the private community was therefore an inadequate rationale for confinement. Additionally, the Court held that the harmless mentally ill may not be institutionalized by the State “solely to save its citizens from exposure to those whose ways are different.” It added:

One might as well ask if the State, to avoid public unease, could incarcerate all who are physically unattractive or socially eccentric. Mere public intolerance or animosity cannot constitutionally justify the deprivation of a person's physical liberty.

“A finding of ‘mental illness’ alone cannot justify a State's locking a person up against his will and keeping him indefinitely in simple custodial confinement. Assuming that that term can be given a reasonably precise content and that the ‘mentally ill’ can be identified with reasonable accuracy, there is still no constitutional basis for confining such persons involuntarily if they are dangerous to no one and can live safely in freedom.” 422 U.S., p. 575.

“May the State confine the mentally ill merely to ensure them a living standard superior to that they enjoy in the private community? That the State has a proper interest in providing care and assistance to the unfortunate goes without saying. But the mere presence of mental illness does not disqualify a person from preferring his home to the comforts of an institution. Moreover, while the State may arguably confine a person to save him from harm, incarceration is rarely if ever a necessary condition for raising the living standards of those capable of surviving safely in freedom, on their own or with the help of family or friends. See Shelton v. Tucker, 364 U. S. 479, 488-490.” 422 U.S., p. 575.

“In short, a State cannot constitutionally confine 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. Since the jury found, upon ample evidence, that O'Connor, as an agent of the State, knowingly did so confine Donaldson, it properly concluded that O'Connor violated Donaldson's constitutional right to freedom.” 422 U.S., p. 576.