O'Connor v. Donaldson
| O'Connor v. Kenneth Donaldson | |
|---|---|
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| Argued January 15, 1975 Decided June 26, 1975 |
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| Full case name | Dr. J. B. O'Connor v. Kenneth Donaldson |
| Citations | 422 U.S. 563 (more) |
| Prior history | Cert. to the U.S. Court of Appeals for the Fifth Circuit |
| Holding | |
| A State cannot constitutionally confine a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsible family members or friends. | |
| Court membership | |
| Case opinions | |
| Majority | Stewart, joined by unanimous |
| Concurrence | Burger |
O'Connor v. Donaldson, 422 U.S. 563 (1975), was a landmark decision in mental health law. The United States Supreme Court ruled that a state cannot constitutionally confine a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsible family members or friends. Since the trial court jury found, upon ample evidence, that petitioner did so confine respondent, the Supreme Court upheld the trial court's conclusion that petitioner had violated respondent's right to liberty.
Kenneth Donaldson (confined patient) had been held for 15 years in Florida State Hospital at Chattahoochee, due to needs of "care, maintenance, and treatment." He filed a lawsuit against the hospital and staff members claiming they had robbed him of his constitutional rights, by confining him against his will. Donaldson won his case (including monetary damages) in United States District Court, won the appeals, and in 1975 the victory was reaffirmed by the Supreme Court.
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.
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. May the State fence in the harmless mentally ill solely to save its citizens from exposure to those whose ways are different? 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. In short, a State cannot constitutionally confine without more a non-dangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends. ...
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