U
U.S. Supreme Court
O'CONNOR v. DONALDSON, 422 U.S. 563
(1975)
422 U.S. 563
O'CONNOR v. DONALDSON.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.
No. 74-8.
Argued January 15, 1975.
Decided June 26, 1975.
Respondent, who was confined almost 15 years "for care, maintenance,
and treatment" as a mental patient in a Florida state hospital, brought
this action for damages under 42 U.S.C. 1983 against petitioner, the hospital's
superintendent, and other staff members, alleging that they had intentionally
and maliciously deprived him of his constitutional right to liberty. The
evidence showed that respondent, whose frequent requests for release had been
rejected by petitioner notwithstanding undertakings by responsible persons to
care for him if necessary, was dangerous neither to himself nor others, and, if
mentally ill, had not received treatment. Petitioner's principal defense was
that he had acted in good faith, since state law, which he believed valid, had
authorized indefinite custodial confinement of the "sick," even if
they were not treated and their release would not be harmful, and that
petitioner was therefore immune from any liability for monetary damages. The
jury found for respondent and awarded compensatory and punitive damages against
petitioner and a codefendant. The Court of Appeals, on broad Fourteenth
Amendment grounds, affirmed the District Court's ensuing judgment entered on
the verdict. Held:
1. 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, and since the jury found, upon ample evidence, that
petitioner did so confine respondent, it properly concluded that petitioner had
violated respondent's right to liberty. Pp. 573-576.
2. Since the Court of Appeals did
not consider whether the trial judge erred in refusing to give an instruction
requested by petitioner concerning his claimed reliance on state law as
SNIPPETS:
O'CONNOR v. DONALDSON, 422 U.S. 563
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.
Respondent, who was confined almost 15 years "for care, maintenance, and treatment"
The evidence showed that respondent, whose frequent requests for release had been rejected by
Petitioner's principal defense was that he had acted in good faith, since state law, which he
The Court of Appeals, on broad Fourteenth Amendment grounds, affirmed the District Court's
Since the Court of Appeals did not consider whether the trial judge erred in refusing to give
liability vel non for monetary damages for violating respondent's constitutional right.
The respondent, Kenneth Donaldson, was civilly committed to confinement as a mental patient
The petitioner, Dr. J. B. O'Connor, was the hospital's superintendent during most of this
The state law was less than clear in specifying the grounds necessary for commitment,
The record shows that Lembcke was a serious and responsible person, who was willing and able
O'Connor's principal defense was that he had acted in good faith and was therefore immune
The trial judge instructed the members of the jury that they should find that O'Connor had
mere good intentions which do not give rise to a reasonable belief that detention is lawfully
The Court of Appeals affirmed the judgment of the District Court in a broad opinion dealing
The appellate court held that when, as in Donaldson's case, the rationale for confinement is
Director, Patuxent Institution, 407 U.S. 245, 248 -250.
But the mere presence of mental illness does not disqualify a person from preferring his home
Accordingly, we vacate the judgment of the Court of Appeals and remand the case to enable
As a justification for a constitutional right to such treatment, the quid pro quo theory
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