Jarvis v. Levine
418 N.W.2d 139, 74 A.L.R. 4th 1079, 1988 Minn. LEXIS 3 (1988)
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Rule of Law:
The involuntary administration of neuroleptic (antipsychotic) drugs to involuntarily committed mental patients constitutes an 'intrusive treatment' and requires prior judicial approval under the Minnesota Constitution's right to privacy and bodily integrity.
Facts:
- Homer Jarvis was indeterminately committed to the Minnesota Security Hospital in March 1977 as mentally ill and dangerous, following the shooting death of his sister.
- Jarvis denies being ill, believes hospital personnel and courts conspired against him, and thinks medications are poisoning him, but he is articulate, intelligent, and has intact self-care skills, with no evidence of current violence.
- Jarvis was involuntarily treated with neuroleptic medication four times during his commitment, experiencing severe side effects such as tremors, blurred vision, akathisia (restlessness), and Parkinsonisms during previous courses of treatment (1977-78, 1978-80, 1981-82).
- In November 1984, Dr. Doheny, Jarvis's treating physician, initiated a request for a fourth course of involuntary neuroleptic treatment after Jarvis refused.
- The Facility Treatment Review Panel (TRP), a multidisciplinary group of mental health professionals, disapproved Dr. Doheny's requests for involuntary medication of Jarvis on seven occasions, finding that potential for serious side effects outweighed benefits and there was no history of clearly documented symptom reduction.
- Despite the TRP's repeated disapprovals, Dr. Gottlieb, the Medical Director, overruled their recommendations multiple times, leading to Jarvis being forcibly medicated with neuroleptics for nine months, from December 1984 to September 1985.
- In July 1985, the TRP expressed concern that Jarvis's medical records indicated the possibility of him developing tardive dyskinesia, a permanent and irreversible neurological condition, yet medication continued until September.
Procedural Posture:
- Jarvis commenced an action in trial court for damages pursuant to 42 U.S.C. § 1983 and for declaratory and injunctive relief, asserting claims including failure to comply with state policy, constitutional rights violations, statutory right to treatment violation, and lack of prior judicial review.
- Respondents moved for summary judgment on all counts, and Jarvis moved for partial summary judgment on the count concerning the right to premedication judicial review.
- The trial court granted respondents’ motion for summary judgment and denied Jarvis’s motion for partial summary judgment, entering judgment.
- Jarvis appealed the judgment to the Minnesota Court of Appeals (Jarvis as appellant, respondents as appellee).
- The Court of Appeals affirmed the judgment with some modification, holding that involuntary neuroleptic treatment was not per se intrusive and did not require premedication judicial review under Price v. Sheppard, but recognized a qualified right to refuse treatment and a right to post-medication review, while finding Jarvis’s damage claim inappropriate.
- The Minnesota Supreme Court granted Jarvis’s petition for further review (Jarvis as appellant, respondents as appellee).
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Issue:
Does involuntary neuroleptic treatment of involuntarily committed mental patients constitute intrusive treatment under Price v. Sheppard, thereby requiring pre-treatment judicial review and approval?
Opinions:
Majority - YETKA, Justice
Yes, involuntary neuroleptic treatment constitutes intrusive treatment, requiring prior judicial approval. The court explicitly holds that the procedures established in Price v. Sheppard must apply to the involuntary administration of neuroleptic drugs. This decision is grounded in the Minnesota Constitution, particularly Article I, Sections 1, 2, and 10, recognizing an independent state right of privacy that protects bodily integrity from unwanted alteration or invasion. The court finds that the potentially devastating side effects of neuroleptic drugs, particularly the risk of permanent and irreversible tardive dyskinesia, are sufficiently severe to categorize them as intrusive, on par with electroconvulsive therapy (ECT) and psychosurgery. While acknowledging the federal 'professional judgment' standard from Youngberg v. Romeo, the court distinguishes it, noting that Youngberg involved a severely retarded patient and different issues, and reaffirms Minnesota's independent responsibility to safeguard its citizens' rights under state law. The existing administrative review process, though commendable in form, is deemed insufficient because a medical director can unilaterally override the recommendations of peer review boards, rendering patient protections meaningless. The court emphasizes that the ultimate decision to accept or reject medical procedures is a personal choice, not solely a medical one, and committed patients retain fundamental rights, including personal autonomy. Therefore, when medical judgments conflict with fundamental rights, courts, not doctors, possess the necessary expertise to ensure protection. While respondents in this specific case are immune from damages because they followed previously established statutory procedures that were presumptively constitutional, all future involuntary neuroleptic treatments will require prior judicial approval.
Concurring - KELLEY, Justice
I concur with the court's conclusion that involuntary neuroleptic treatment requires prior judicial approval. This outcome is sufficiently supported by existing Minnesota Statutes and a long line of common law cases protecting bodily integrity, as well as the precedent set by Price v. Sheppard. Therefore, I do not believe it is necessary for the majority to base its decision on Sections 1, 2, and 10 of the Minnesota Constitution, as the existing legal framework provides adequate grounds for the ruling.
Analysis:
This case significantly expands patient autonomy rights for involuntarily committed individuals in Minnesota by classifying neuroleptic medication as an 'intrusive treatment.' It firmly establishes an independent state constitutional right to privacy and bodily integrity, distinct from federal constitutional standards, strengthening individual protections against involuntary medical interventions. The decision mandates a shift from purely medical discretion to judicial oversight when medical professionals disagree or when treatments are highly intrusive, thereby ensuring that fundamental rights are protected by a neutral arbiter. This ruling serves as a powerful precedent for future cases involving patient rights in mental health contexts, emphasizing that commitment does not equate to a forfeiture of fundamental constitutional protections.
