United States Supreme Court cases involving mental health
The U.S. Supreme Court has issued numerous rulings regarding mental health and how society treats and regards the mentally ill. While some rulings applied very narrowly, perhaps to only one individual, other cases have had great influence over wide areas.
Year |
Case |
Ruling |
Right |
|
|
ADA |
|
1999 |
Albertsons Inc. v. Kirkingburg |
the Court held that not all individuals who suffer some sort of physical difficulty are per se "disabled" under the ADA. Instead, those who believe they suffer from a disability must prove their claim on a case-by-case basis by showing that their alleged disability substantially impacts on a major life activity |
??? |
Year |
Case |
Ruling |
Right |
|
|
CRIMINAL COMPETENCY |
|
1960 |
Dusky v. United States |
Affirming a criminal defendant's constitutional right to have a competency evaluation before proceeding to trial, and setting the standard for determination of such competence. |
BOR, 14th |
1966 |
Pate v. Robinson |
A hearing regarding competency is necessary under the due process clause of the Constitution of the United States. |
BOR, 14th |
1972 |
Jackson v. Indiana |
Criminal defendants who have been found incompetent to stand trial are not permitted to be held indefinitely. There must be some possibility of becoming competent in a reasonable amount of time |
BOR, 14th |
1975 |
Drope v. Missouri |
When deciding whether to evaluate a criminal defendant's competency, the court must considered any evidence suggestive of mental illness, even one factor alone in some circumstances. Therefore, the threshold for obtaining a competency evaluation is low. When the issue is raised, the motion should be granted. The defendant must not bear all the burden for raising the issue. |
BOR, 14th |
1985 |
Ake v. Oklahoma |
Indigent criminal defendants have a right to a competency evaluation |
BOR, 14th |
1996 |
Cooper v. Oklahoma |
the burden for proving incompetency is only preponderance; due process would be violated if the burden is required to be carried by clear and convincing evidence. |
|
Year |
Case |
Ruling |
Right |
|
|
DEATH PENALTY |
|
1986 |
Ford v. Wainright |
Preventing the execution [capital punishment] of the insane, requiring an evaluation of competency and an evidentiary hearing] |
1st |
1993 |
Godinez v. Moran |
Competency to stand trial includes the abilities to plead guilty and to waive the right to counsel |
1st |
1976 |
Profitt v. Florida |
Permitted comparison of mitigating (including mental health reasons) and aggravating factors to decide death penalty decisions. See also Furman v. Georgia (1972), and Gregg v. Georgia (1976)) |
1st |
2005 |
Roper v. Simmon |
In a ruling that followed Wainright (in assessing the nature of cruel and unusual punishments), children may not be given the death penalty |
1st |
2010 |
Graham v. Florida |
Likewise, children may not be given life sentences (without possibility of parole) for offenses that do not include murder |
1st |
Year |
Case |
Ruling |
Right |
|
|
INSANITY |
|
1978 |
Lockett v. Ohio |
Sentencing authorities must have the discretion to consider every possible mitigating factor, rather than being limited to a specific list of factors. |
1st |
Year |
Case |
Ruling |
Right |
|
|
TESTIMONY |
|
1981 |
Estelle v. Smith |
The same doctor that evaluated the criminal defendant for competency also testified at the penalty phase of the trial. That violated the defendant's right against self incrimination. |
5th, 6th |
Year |
Case |
Ruling |
Right |
|
|
RIGHT TO TREATMENT |
|
1976 |
Estelle v. Gamble |
Established that Prisoners are a minimum level of treatment, including mental health care |
8th |
Year |
Case |
Ruling |
Right |
|
|
RIGHT TO REFUSE TREATMENT |
|
1978 |
Rennie v. Klein |
CIVIL-an involuntarily committed, legally competent patient who refused medication had a right to professional medical review of the treating psychiatrist's decision. The Court left the decision-making process to medical professionals. |
14th |
1990 |
Washington v. Harper |
CRIMINAL-Prisoners have only a very limited right to refuse psychotropic medications in prison. The needs of the institution take precedence over the prisoners' rights. However, there must be a formal institutional hearing, the prisoner must be found to be dangerous to himself or others, the prisoner must be diagnosed with a serious mental illness, and the mental health care professional must state that the medication prescribed is in the prisoner's best interest. |
14th |
1992 |
Riggins v. Nevada |
CRIMINAL-In a ruling very similar to Harper, the Court found that the State may force administration of psychotropic medications to a pre-trial detainee, if it establishes a medical need for the drug, and a need for the detainee's safety and that of others. To the Harper requirements, they added "less restrictive alternative" language, which requires the State to document that there are no behavioral, environmental, or other measures available that will be equally effective. |
6th, 14th |
Year |
Case |
Ruling |
Right |
|
|
CIVIL COMMITMENT |
|
1972 |
Jackson v. Indiana |
due process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is committed.” Reasoning that if commitment is for treatment and betterment of individuals, it must be accompanied by adequate treatment, several lower courts recognized a due process right |
14th |
1979 |
Addington v. Texas |
Raised the burden of proof requirement, in order to civilly commit a person, from preponderance, to clear and convincing. Also, permitted the courts to defer judgment regarding a person's need for commitment, to the doctor(s) |
14th |
1979 |
Parham v. JR |
The Court ruled that minors may be civilly committed to mental health facilities without an adversary hearing; in essence, parents do have the right to commit their children. |
14th |
1982 |
Youngberg v. Romeo |
Each individual has a due process protected interest in freedom from confinement and personal restraint; an interest in reducing the degree of confinement continues even for those individuals who are properly committed. freedom from undue physical restraint and from unsafe conditions of confinement |
14th |
1974 |
Donaldson v. O'Connor |
In terms of impact, Connor v. Donaldson, may be the single most important decision in mental health law. It has been used by opponents of involuntary commitment to argue that civil commitment be limited to only mentally ill and dangerous persons. This interpretation has been important in hampering efforts to implement changes in commitment law (limiting access to treatment).
The Court stated, "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… In short, a state cannot constitutionally confine without more a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends."
|
1993 |
Heller v. Doe |
Reflecting the more conservative ('pro-government') attitude of the times, the Court found that mentally retarded persons are not a 'suspect' class of persons (requiring the same level of protection as racial minorities); thus, governments are free to enact almost any legislation or rule to civilly commit them, and the courts will not intervene, short of illegal or ridiculous actions (called 'rational' scrutiny). |
14th |
Year |
Case |
Ruling |
Right |
|
|
????????????????????? |
|
1988 |
Lowenfield v. Phelps |
Found that the function of restricting the class of murderers eligible for capital punishment can be accomplished by explicit law or by findings of aggravating circumstances |
1988 |
Thompson v. Oklahoma |
Executions of offenders age fifteen and younger at the time of their crimes is unconstitutional under Eighth Amendment. |
1989 |
Stanford v. Kentucky |
Eighth Amendment does not prohibit the death penalty for crimes committed at age sixteen or seventeen. (Overturned in Roper v. Simmons (2005)) |
1989 |
Penry v. Lynaugh |
Executing persons with mental retardation is not a violation of the Eighth Amendment. (Overturned in Atkins v. Virginia (2002)) |
1990 |
Walton v. Arizona |
Found judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved" are not unconstitutionally vague. (First finding overturned in Ring v. Arizona (2002)) |
1992 |
Morgan v. Illinois |
A defendant may challenge for cause a prospective juror who would automatically vote to impose the death penalty in every capital case |
1993 |
Herrera v. Collins |
In the absence of other constitutional grounds, new evidence of innocence is no reason for federal court to order a new trial. |
1995 |
Schlup v. Delo |
Expanded the ability to reopen a case in light of new evidence of innocence |
2002 |
Ring v. Arizona |
A death sentence where the necessary aggravating factors are determined by a judge violates a defendant's constitutional right to a trial by jury. |
2002 |
Atkins v. Virginia |
The execution of mentally retarded defendants violates the Eighth Amendment's ban on cruel and unusual punishment. |
2004 |
Tennard v. Dretke |
Held that all relevant mitigating factors must be considered in the penalty phase of a death penalty case, not just in the trial phase |
2004 |
Schriro v. Summerlin |
Held that a requirement from the Ring decision requiring the jury rather than the judge to find aggravating factors would not be applied retroactively. |
2005 |
Roper v. Simmons |
The death penalty for those who had committed their crimes under 18 years of age is cruel and unusual punishment and violates the Eighth Amendment. |
2006 |
Oregon v. Guzek |
States may limit the evidence of innocence a defendant may present at his sentencing hearing to evidence already presented at his trial. |
2006 |
Hill v. McDonough |
Allowed appeal on civil rights violation grounds, even after habeas appeal |
2006 |
Kansas v. Marsh |
States not prohibited from imposing the death penalty when mitigating and aggravating sentencing factors were both present. |
2006 |
House v. Bell |
Post-conviction DNA forensic evidence can be considered in death penalty appeals. |
2008 |
Medellin v. Texas |
A requirement imposed by a treaty is not binding unless it was enacted by a statute created by Congress. |
2008 |
Baze v. Rees |
Found Kentucky's lethal injection method did not violate the Eighth Amendment |
2008 |
Kennedy v. Louisiana |
States may not impose the death penalty for a crime "where the victim's life was not taken" |
2009 |
Harbison v. Bell |
Indigent death row inmates sentenced under state law have a right to federally-funded habeas counsel in post-conviction state clemency proceedings, when the state has denied such counsel. |
References
See also