Youngberg v. Romeo
457 U.S. 307 (1982)
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Rule of Law:
Involuntarily committed mentally retarded persons have substantive due process rights under the Fourteenth Amendment to safe conditions, freedom from undue bodily restraint, and minimally adequate training. Liability for violating these rights may be imposed only when a decision by a professional represents a substantial departure from accepted professional judgment, practice, or standards.
Facts:
- Nicholas Romeo, a profoundly mentally retarded man with the mental capacity of an 18-month-old, was involuntarily committed to Pennsylvania's Pennhurst State School and Hospital by his mother.
- Following his father's death, Romeo's mother could no longer control his violent behavior and sought his admission to the state facility.
- While at Pennhurst, Romeo suffered injuries on at least sixty-three occasions, resulting from his own actions and his interactions with other residents.
- After being transferred to the hospital ward for a broken arm, Romeo was physically restrained for portions of each day by doctor's orders to protect himself and others.
- Romeo's mother alleged that the restraints were being used routinely and that the institution was failing to provide him with appropriate treatment or programs for his mental retardation.
- Pennhurst staff had designed a behavior-modification program to reduce Romeo's aggressive behavior, but it was never implemented because his mother objected to it.
Procedural Posture:
- Nicholas Romeo's mother, as his next friend, filed a lawsuit under 42 U.S.C. § 1983 against three Pennhurst administrators in the United States District Court for the Eastern District of Pennsylvania.
- The complaint alleged violations of Romeo's Eighth and Fourteenth Amendment rights and sought damages.
- At the conclusion of an 8-day trial, the jury was instructed using an Eighth Amendment 'deliberate indifference' standard.
- The jury returned a verdict in favor of the defendants (the administrators).
- Romeo (appellant) appealed the decision to the U.S. Court of Appeals for the Third Circuit.
- The Court of Appeals, sitting en banc, reversed the trial court's judgment and remanded for a new trial, finding the Fourteenth Amendment, not the Eighth, was the proper source of Romeo's rights.
- The Pennhurst administrators (petitioners) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment grant involuntarily committed mentally retarded persons substantive rights to safe conditions of confinement, freedom from bodily restraints, and minimally adequate training?
Opinions:
Majority - Justice Powell
Yes, involuntarily committed mentally retarded persons retain constitutionally protected liberty interests under the Due Process Clause. These interests include the right to safe conditions and the right to freedom from undue bodily restraint. Furthermore, these individuals are entitled to minimally adequate or reasonable training necessary to ensure their safety and freedom from undue restraint. The Court established that the proper standard for determining if these rights have been violated is the 'professional judgment' standard. A decision made by a professional is presumptively valid and liability can be imposed only when the decision is such a substantial departure from accepted professional judgment, practice, or standards as to demonstrate that the person did not actually base the decision on such a judgment. This standard balances the individual's liberty interests against the state's legitimate interests in operating its institutions, while giving necessary deference to the judgments of qualified professionals.
Concurrence - Justice Blackmun
Yes, I agree with the Court's opinion but write to clarify two unresolved issues. The first is whether a state that commits an individual for 'care and treatment' can constitutionally refuse to provide any treatment at all. The second is whether an individual has an independent constitutional right to habilitation necessary to preserve the basic self-care skills they possessed upon entering the institution. These are serious constitutional questions that remain open because the record in this case is not sufficiently developed to address them.
Concurrence - Chief Justice Burger
Yes, I agree with the judgment but would hold that there is no constitutional right to training or 'habilitation' per se. The state's obligation is fulfilled by providing food, shelter, medical care, and reasonably safe living conditions. Training is only constitutionally required to the extent it is necessary to avoid unreasonable infringement of a person's interests in safety and freedom from restraint, and not as an independent, affirmative duty of the state.
Analysis:
This case is significant as it was the first time the Supreme Court recognized the substantive due process rights of involuntarily committed individuals with mental retardation. The Court established a new constitutional standard, 'professional judgment,' which is more protective than the Eighth Amendment's 'deliberate indifference' standard used for prisoners but less stringent than a 'compelling necessity' test. This intermediate standard provides a framework for lower courts to balance the fundamental liberties of institutionalized persons against the operational realities and professional expertise within state facilities. The decision solidifies that institutionalized individuals are not stripped of their constitutional rights and imposes a duty on the state to provide care that meets professional standards, while also protecting state officials from liability for reasonable professional decisions.
