Youngberg v. Romeo

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 to a Pennsylvania State institution upon his mother's petition, was injured on numerous 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. She claimed that they had thereby violated her son's rights under the Eighth and Fourteenth Amendments. She also filed a second amended complaint, alleging that the officials were restraining her son for prolonged periods on a routine basis 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 not an 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 individuals have 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 also wrote 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 left unresolved, 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.