O'Connor v. Donaldson

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O'Connor v. Kenneth Donaldson
Supreme Court of the United States
Argued January 15, 1975
Decided June 26, 1975
Full case name: Dr. J. B. O'Connor v. Kenneth Donaldson
Citations: 422 U.S. 563; 95 S. Ct. 2486; 45 L. Ed. 2d 396; 1975 U.S. LEXIS 81
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
Chief Justice: Warren E. Burger
Associate Justices: William O. Douglas, William J. Brennan, Jr., Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist
Case opinions
Majority by: Stewart
Joined by: unanimous
Concurrence by: 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 states could not confine citizens to an institution (or similar) if they were non-dangerous and capable of living by themselves, or with the aid of responsible family or friends.

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. Having won his case in United States District Court, he won the appeals, and in 1975 the victory was reaffirmed by the Supreme Court.

[edit] Kenneth Donaldson

The origins of Donaldson's institutionalization began in 1943 - at age 43 -, when he suffered a trauma episode. He was hospitalized and received treatment, before resuming life with his family. However, in 1950s he developed paranoid delusions, and was committed to the state hospital of Chattahoochee, Florida in 1956. He spent 15 years as a patient; though he did not receive any treatment, actively refusing it, and attempting to secure his release. Throughout his stay he denied he was ever ill, and refused to be put into a half-way house.

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