Petitioners
Duane Youngberg, Superintendent, Penhurst State School and Hospital, et al.
Respondents
Nicholas Romeo, an incompetent, by his mother, Paula Romeo
Petitioners' Claim
That the proper standard of liability is the Eighth Amendment, and that the Pennsylvania State Institution properly adhered to the standards of the law intreating the respondent's son, a severely mentally handicapped individual.
Chief Lawyer for Petitioners
David H. Allshouse
Chief Lawyer for Respondents
Edmond A. Tiryak
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr. (writing for the Court), William H. Rehnquist, John Paul Stevens, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
18 June 1982
Decision
Involuntarily committed retarded persons were held to have due process liberty interests requiring state to provide minimally adequate training to ensuresafety and freedom from undue restraint.
Significance
Individuals are constitutionally protected under the Due Process Clause of the Fourteenth Amendment to reasonably safe conditions on confinement. The proper method for determining whether the state has protected those rights is whether professional judgment was exercised, showing deference to the judgment exercised by a qualified professional, whose decision is preemptively valid.
Nicholas Romeo, a mentally retarded person who was involuntarily committed toa Pennsylvania State institution upon his mother's petition, was injured onnumerous occasions while a patient at the institution. Paula Romeo, his mother, filed a complaint in the U.S. District Court for the Eastern District of Pennsylvania seeking damages against the institution's officials, alleging that these officials knew, or should have known, that her son was suffering injuries and that they failed to institute appropriate preventive procedures. Sheclaimed that they had thereby violated her son's rights under the Eighth andFourteenth Amendments. She also filed a second amended complaint, alleging that the officials were restraining her son for prolonged periods on a routinebasis and claiming damages for the officials' failure to provide him with appropriate treatment or programs for his mental retardation. At the close of trial, the district court instructed the jury on the assumption that the proper standard of liability was that of the Eighth Amendment, and a verdict was returned for the official. The U.S. Court of Appeals for the Third Circuit reversed and remanded for a new trial, holding that the Eighth Amendment was notan appropriate source for determining the rights of the involuntarily committed, but that the Fourteenth Amendment, and the liberty interest protected therein, provided the proper constitutional basis for these rights.
On certiorari, the U.S. Supreme Court vacated and remanded. In an opinion written by Justice Powell, it was held that mentally retarded individualshave liberty interests under the Due Process Clause of the Fourteenth Amendment which required the state to provide him with minimally adequate or reasonable training to ensure safety and freedom from undue restraint. Powell alsowrote that the state was under a duty to provide the mentally retarded with such training as an appropriate professional would consider reasonable to ensure the safety of the patient and to facilitate the patient's ability to function free from bodily restraints.
In a concurring decision written by Justice Blackmun and joined by Justices Brennan and O'Connor, Blackmun expressed the view that the Court properly leftunresolved, because of the less-than-fully developed record, the issues as to the individual committed under state law for care and treatment. However, Chief Justice Burger, concurring in the judgment but in a separate decision, stated that a mentally retarded person involuntarily committed to a state institution, had no constitutional right to training, or habilitation.
Related Cases
Duane Youngberg, Superintendent, Penhurst State School and Hospital, et al.
Respondents
Nicholas Romeo, an incompetent, by his mother, Paula Romeo
Petitioners' Claim
That the proper standard of liability is the Eighth Amendment, and that the Pennsylvania State Institution properly adhered to the standards of the law intreating the respondent's son, a severely mentally handicapped individual.
Chief Lawyer for Petitioners
David H. Allshouse
Chief Lawyer for Respondents
Edmond A. Tiryak
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr. (writing for the Court), William H. Rehnquist, John Paul Stevens, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
18 June 1982
Decision
Involuntarily committed retarded persons were held to have due process liberty interests requiring state to provide minimally adequate training to ensuresafety and freedom from undue restraint.
Significance
Individuals are constitutionally protected under the Due Process Clause of the Fourteenth Amendment to reasonably safe conditions on confinement. The proper method for determining whether the state has protected those rights is whether professional judgment was exercised, showing deference to the judgment exercised by a qualified professional, whose decision is preemptively valid.
Nicholas Romeo, a mentally retarded person who was involuntarily committed toa Pennsylvania State institution upon his mother's petition, was injured onnumerous occasions while a patient at the institution. Paula Romeo, his mother, filed a complaint in the U.S. District Court for the Eastern District of Pennsylvania seeking damages against the institution's officials, alleging that these officials knew, or should have known, that her son was suffering injuries and that they failed to institute appropriate preventive procedures. Sheclaimed that they had thereby violated her son's rights under the Eighth andFourteenth Amendments. She also filed a second amended complaint, alleging that the officials were restraining her son for prolonged periods on a routinebasis and claiming damages for the officials' failure to provide him with appropriate treatment or programs for his mental retardation. At the close of trial, the district court instructed the jury on the assumption that the proper standard of liability was that of the Eighth Amendment, and a verdict was returned for the official. The U.S. Court of Appeals for the Third Circuit reversed and remanded for a new trial, holding that the Eighth Amendment was notan appropriate source for determining the rights of the involuntarily committed, but that the Fourteenth Amendment, and the liberty interest protected therein, provided the proper constitutional basis for these rights.
On certiorari, the U.S. Supreme Court vacated and remanded. In an opinion written by Justice Powell, it was held that mentally retarded individualshave liberty interests under the Due Process Clause of the Fourteenth Amendment which required the state to provide him with minimally adequate or reasonable training to ensure safety and freedom from undue restraint. Powell alsowrote that the state was under a duty to provide the mentally retarded with such training as an appropriate professional would consider reasonable to ensure the safety of the patient and to facilitate the patient's ability to function free from bodily restraints.
In a concurring decision written by Justice Blackmun and joined by Justices Brennan and O'Connor, Blackmun expressed the view that the Court properly leftunresolved, because of the less-than-fully developed record, the issues as to the individual committed under state law for care and treatment. However, Chief Justice Burger, concurring in the judgment but in a separate decision, stated that a mentally retarded person involuntarily committed to a state institution, had no constitutional right to training, or habilitation.
Related Cases
- Ingram v. Wright, 430 U.S. 651 (1977).
- Hutto v. Finney, 437 U.S. 678 (1978).
- Harris v. McRae, 448 U.S. 297 (1980).
Further Readings
- "Due Process of Law; Incompetent or Insane Persons; Mental Illness."AIR Quick Index.
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