Youngberg v. Romeo

Facts of the Case

Plaintiff Romeo, a minor, was involuntarily committed to the Pennhurst State School and Hospital, a state institution for the mentally retarded.  After he had been injured on numerous occasions while a patient at the institution, Romeo, by and through his mother as next friend, brought an action against defendants, a Pennsylvania state institution and its officials, for violation of his constitutional rights under the Civil Rights Act of 1871. The district court entered judgment for defendants institution and the State officials, but the Court of Appeals  for the Third Circuit reversed and remanded. Defendants petitioned for certiorari review.

Question

(1) Does the Due Process Clause of the Fourteenth Amendment grant an involuntarily committed patient the right to safe confinement?(2) Does the Due Process Clause of the Fourteenth Amendment grant an involuntarily committed patient the right to freedom from bodily restraints?(3) Does the Due Process Clause of the Fourteenth Amendment grant an involuntarily committed patient the right to adequate habilitation?

CONCLUSION

Yes, yes, unanswered. Justice Lewis F. Powell, Jr. delivered the opinion for the unanimous Court. The Court held that the involuntarily committed do have liberty interests in safe confinement and freedom from bodily restraint under the Fourteenth Amendment. However, a historical right to adequate habilitation was less clear, made especially so by the facts of the case in question. Because no amount of habilitation would allow Romeo to live independently, the Court was unsure what would qualify as adequate habilitation. The Court held that Romeo’s liberty interests required Pennhurst to provide adequate habilitation, but only as it related to Romeo’s right to safe confinement and freedom from undue restraint. The Court declined to answer whether the Fourteenth Amendment includes a stand-alone right to adequate habilitation, or how to determine the level of habilitation required to protect other liberty interests under the Fourteenth Amendment. The Court emphasized the need to balance the legitimate interests of both parties involved to determine whether liberty interests were being adequately protected. In the involuntary commitment arena, deference to qualified professionals is necessary because of their specialized knowledge and the specific circumstances and risks inherent in a mental hospital. Therefore, such professionals and institutions can only be held liable for infringements on liberty interests when the decision by a professional is a substantial departure from accepted professional judgment.Justice Harry A. Blackmun wrote a concurrence emphasizing that the majority opinion had correctly not ruled on whether a state can accept an individual for care and then refuse treatment or whether the right to habilitation required Pennhurst to offer adequate training to preserve Romeo’s original basic self-care skills. He argued that the record was not adequately developed to address these two issues. Justice William J. Brennan, Jr. and Justice Sandra Day O’Connor joined in the concurrence. In his separate concurrence, Chief Justice Warren E. Burger wrote that the Fourteenth Amendment did not contained a separate right to habilitation. Any right to habilitation only arises from other liberty interests, not as a liberty interest in and of itself.

Case Information

  • Citation: 457 US 307 (1982)
  • Argued: Jan 11, 1982
  • Decided Jun 18, 1982