Parham v. J.R.

Supreme Court of United States
442 U.S. 584 (1979)

ELI5:

Rule of Law:

The Due Process Clause of the Fourteenth Amendment does not require a formal, adversary hearing before a minor child may be voluntarily committed to a state mental institution by their parent or guardian. The process is constitutionally sufficient so long as the commitment is approved by an independent medical judgment of a neutral physician after a thorough inquiry, and the child's need for continued confinement is periodically reviewed.

Facts:

At age 6, J.L. was admitted to a Georgia state mental hospital at his mother's request after she reported he was uncontrollable and he had received prior outpatient treatment.
The admitting physician diagnosed J.L. with a 'hyperkinetic reaction of childhood' after interviewing the child and his parents.
After a trial furlough at home proved unsuccessful, J.L.'s parents requested his readmission, and they later relinquished their parental rights to the county.
J.R., a neglected child, was placed in seven different foster homes after being removed from his parents at three months old.
At age 7, after being disruptive at school, J.R.'s seventh set of foster parents requested his removal from their home.
The Georgia Department of Family and Children Services, acting as J.R.'s guardian, sought his admission to a state hospital.
After conducting interviews and reviewing J.R.'s history, hospital staff diagnosed him with an 'unsocialized, aggressive reaction of childhood' and determined he would benefit from the hospital's structured environment.

Procedural Posture:

J.R., on behalf of a class of minors, filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Middle District of Georgia against state officials.
A three-judge District Court was convened to hear the case.
The District Court held that Georgia’s voluntary commitment procedures for minors violated the Due Process Clause of the Fourteenth Amendment.
The District Court issued an injunction against future commitments under the challenged statute and ordered the state to provide non-hospital treatment alternatives.
The Georgia state officials, as appellants, appealed the District Court's judgment directly to the Supreme Court of the United States.

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Issue:

Does Georgia's statutory scheme for the voluntary commitment of a minor child to a state mental hospital by a parent or guardian, which does not require a formal adversary hearing, violate the Due Process Clause of the Fourteenth Amendment?

Opinions:

Majority - Chief Justice Burger

No, Georgia's statutory scheme for the voluntary commitment of a minor child does not violate the Due Process Clause of the Fourteenth Amendment. The Court applied the Mathews v. Eldridge three-part balancing test. It recognized a child's substantial liberty interest but also affirmed the traditional presumption that parents act in their children's best interests. A formal, adversary hearing poses a significant risk to the parent-child relationship and may deter parents from seeking necessary care. The risk of an erroneous deprivation of liberty is sufficiently minimized by requiring a 'neutral factfinder'—a staff physician—to conduct a thorough inquiry into the child's background, interview the child, and make an independent medical judgment about the need for institutionalization, followed by periodic reviews of the need for continued commitment. This 'medical model' of due process adequately protects the child’s rights without unduly burdening the state or undermining parental authority.

Concurring - Justice Stewart

No. The long-standing common law principle is that parents speak for their minor children. A parent's decision to seek state-administered mental health care for their child is a private decision, not a state action that deprives the child of liberty in the constitutional sense, much like a parent's decision to authorize surgery. Even if the greater loss of liberty in commitment triggers constitutional scrutiny, the objective checks within Georgia's system—namely, the requirement of a professional medical evaluation and approval—are more than constitutionally sufficient to safeguard the child's interests.

Concurring-in-part-and-dissenting-in-part - Justice Brennan

No and Yes. The majority is correct that a formal, pre-admission adversary hearing is not required when a parent seeks to commit their child, as this could deter parents and damage family relationships. However, the informal post-admission reviews conducted by the hospital are constitutionally deficient and a reasonably prompt, formal post-admission hearing is required to satisfy due process. Furthermore, when the state acts as guardian (in loco parentis), the presumption of acting in the child's best interest is weaker and the concerns for family autonomy are absent; therefore, wards of the state are constitutionally entitled to a full, pre-admission adversary hearing before being committed.

Analysis:

This decision establishes a 'medical model' of due process for juvenile mental health commitments, rejecting a more formal 'judicial model.' It affirms the traditional legal presumption of parental authority in medical decision-making while recognizing the child's liberty interest requires a procedural safeguard. The holding balances the child's rights, parental authority, and the state's interest in providing accessible mental health care. By finding that an independent medical evaluation is a sufficient substitute for an adversarial hearing, the Court set a precedent that avoids making the process of seeking mental health care for minors overly litigious or burdensome for parents and the state.

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