O'Connor v. Donaldson

RESPONDENT: Kenneth Donaldson
LOCATION: Florida State Hospital

DOCKET NO.: 74-8
DECIDED BY: Burger Court (1972-1975)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 422 US 563 (1975)
ARGUED: Jan 15, 1975
DECIDED: Jun 26, 1975
GRANTED: Oct 21, 1974

Bruce J. Ennis - for respondent
Raymond W. Gearey, Jr. - for petitioner, pro hac vice, by special leave of Court

Facts of the case

On January 3, 1957, Kenneth Donaldson was committed on the petition of his father, following a brief hearing before a county judge. Twelve days later, he was admitted to Florida State Hospital and soon thereafter diagnosed as a paranoid schizophrenic. The committing judge told Donaldson that he was being sent to the hospital for “a few weeks”. Instead, he was confined for almost fifteen years.

When Donaldson was admitted in 1957, J.B. O’Connor was Assistant Clinical Director of the hospital; O’Connor was also Donaldson’s attending physician until he transferred wards on April 18, 1967. John Gumanis was a staff physician for Donaldson’s ward. Donaldson was denied grounds privileges by Gumanis and confined to a locked building with sixty closely-quartered beds. As a Christian Scientist, Donaldson refused to take any medication or to submit to electroshock treatments. According to Donaldson, he received cognitive therapy from O’Connor no more than six times. In essence, the hospital provided Donaldson with subsistence-level custodial care, and a minimal amount of psychiatric treatment. Donaldson challenged his continued commitment several times, but each challenge was denied with little explanation.

In February 1971, Donaldson charged O’Connor and other members of the hospital’s staff under § 1983 with intentionally and maliciously depriving him of his constitutional right to liberty. Evidence at trial showed that the staff had the power to release a mentally ill, committed patient if he was not dangerous to himself or others, but that the staff did not exercise this power. The jury trial found in favor of Donaldson, assessing both compensatory and punitive damages against O’Connor and Gumanis. O’Connor appealed his case separately, and the United States Court of Appeals for the Fifth Circuit, affirmed the jury’s verdict. The court rejected O’Connor’s argument that the trial court improperly barred the jury from finding that O’Connor acted in good faith. The jury instruction was valid because it explicitly stated that the defendants’ reasonable belief that Donaldson’s confinement was proper would preclude damages. Any reliance on state law would fall under this consideration of O'Connor's good faith intentions.


Did the Fifth Circuit properly consider the trial court's failure to instruct the jury on O’Connor’s claimed reliance on state law?

Media for O'Connor v. Donaldson

Audio Transcription for Oral Argument - January 15, 1975 in O'Connor v. Donaldson

Audio Transcription for Opinion Announcement - June 26, 1975 in O'Connor v. Donaldson

Warren E. Burger:

The judgment and opinion of the Court in 74-8, O'Connor against Donaldson will be announced by Mr. Justice Stewart.

Potter Stewart:

This case is here by way of a writ of certiorari to the United States Court of Appeals for the Fifth Circuit.

The respondent, Kenneth Donaldson, was civilly committed to confinement as a mental patient in the Florida State Hospital at Chattahoochee in 1957.

He was kept in custody there against his will for nearly 15 years.

The petitioner, Dr. J. B. O'Connor, was the hospital's superintendent during most of that period.

Throughout his confinement Donaldson repeatedly, but unsuccessfully, demanded his release, claiming that he was dangerous to no one, that he was not mentally ill, and that, at any rate, the hospital was not providing treatment for his supposed illness.

Finally, in 1971, Donaldson brought this lawsuit under Section 1983 of Title 42 of the United States Code in the United States District Court for the Northern District of Florida, alleging that O'Connor, and other members of the hospital staff had intentionally and maliciously deprived him of his constitutional rights.

After a four-day trial, the jury returned a verdict assessing both compensatory and punitive damages against O'Connor and a codefendant.

The Court of Appeals for the Fifth Circuit affirmed that judgment.

We granted O'Connor's petition for certiorari because of the important constitutional questions seemingly presented.

Donaldson's commitment was initiated by his father, who thought that his son was suffering from "delusions."

After hearings before a county judge of Pinellas County, Florida, Donaldson was committed for care, maintenance, and treatment pursuant to Florida statutory provisions that have since been repealed.

The state law was less than clear in specifying the grounds necessary for commitment at that time, and the record is scanty as to Donaldson's condition at the time of the judicial hearing.

These matters are, however, irrelevant, for this case involves no challenge to the initial commitment, but is focused, instead, upon the nearly 15 years of confinement that followed.

The testimony at the trial demonstrated, without contradiction, that Donaldson had posed no danger to others during his long confinement, or indeed at any point in his life.

There was no evidence that Donaldson had ever been suicidal or been thought likely to inflict injury upon himself.

One of O'Connor's codefendants acknowledged that Donaldson could have earned his own living outside the hospital.

He had done so for some 14 years before his commitment, and immediately upon his release he secured a responsible job in hotel administration.

Furthermore, Donaldson's frequent request for -- requests for release had been supported by responsible persons willing and able to provide him any care he might need on release.

The evidence showed that Donaldson's confinement was a simple regime of enforced custodial care, not a program designed to alleviate or cure his supposed illness.

O'Connor described Donaldson's treatment as "milieu therapy."

But witnesses from the hospital staff conceded that, in the context at least of this case, "milieu therapy" was a euphemism for confinement in the "milieu" of a mental hospital.

For substantial periods, Donaldson was simply kept in a large room that housed 60 patients, many of whom were under criminal commitment.

At the trial, O'Connor's principal defense was that he had acted in good faith and was therefore immune from any liability for monetary damages.

His position, in short, was that state law, which he had believed valid, had authorized indefinite custodial confinement of the mentally ill even if they were not given treatment and even if their release could harm no one.

The trial judge instructed the members of the jury that they should find that O'Connor had violated Donaldson's constitutional rights if they found that he had confined Donaldson against his will, knowing that he was not mentally ill or dangerous or knowing that if mentally ill he was not receiving treatment for his alleged mental illness.

The jury returned a verdict for Donaldson against O'Connor and a codefendant, and awarded damages of $38,500, which including $10,000 in punitive damages.

The Court of Appeals affirmed the judgment of the District Court in a broad opinion dealing, and I'm quoting with "the far-reaching question whether the Fourteenth Amendment guarantees a right to treatment to persons involuntarily civilly committed to state mental hospitals."

The appellate court held that when, as in Donaldson's case, the rationale for confinement is that the patient is in need of treatment, the Constitution requires that minimally adequate treatment in fact be provided.

The Court further expressed the view that, regardless of the grounds for involuntary civil commitment, a person confined against his will at a state mental institution has a constitutional right to receive such individual treatment as will give him a reasonable opportunity to be cured or to improve his mental condition.