## Facts

- California physicians and two pseudonymous mental health patients challenged amendments regulating psychosurgery and electroconvulsive therapy (ECT) under the Lanterman-Petris-Short Act.
- One patient sought or anticipated ECT; another desired psychosurgery; petitioners alleged the amendments impeded treatment even when patients were competent and voluntarily admitted.
- The amendments imposed detailed informed-consent requirements, capacity determinations, and committee review/approval structures for psychosurgery and ECT.
- The scheme included (among other provisions) mandatory notice to a “responsible relative,” treatment conditions framed in terms such as “critical need,” and specified professional qualifications for review committee members.
- Petitioners filed an original writ proceeding seeking to restrain enforcement of challenged provisions as unconstitutional.

## Issues

1. Whether statutory standards such as “critical need” were unconstitutionally vague under due process principles.
2. Whether mandatory notification of a “responsible relative” violated a competent patient’s constitutional privacy rights in medical decision-making.
3. Whether applying heightened review and approval requirements to voluntary, competent patients impermissibly burdened autonomy and equal protection interests.
4. Whether the scheme was a permissible exercise of the state’s police power to regulate high-risk psychiatric procedures.
5. Whether unconstitutional provisions were severable from the remainder of the regulatory framework.

## Decision

- The court upheld the state’s general authority to regulate psychosurgery and ECT and sustained many consent, capacity, and review safeguards, particularly for involuntary or incompetent patients.
- The court invalidated provisions requiring disclosure to a “responsible relative” when applied to competent patients who voluntarily sought treatment, as an unconstitutional intrusion on privacy.
- The court held the “critical need” standard unconstitutional for vagueness because it failed to give adequate guidance to physicians, review bodies, and courts and invited arbitrary enforcement.
- The court accepted requirements that review committees include appropriately specialized, board-certified physicians as reasonably related to patient protection.
- The court concluded that certain unconstitutional elements were not cleanly severable where removal would require judicial reconstruction of the legislative scheme; dependent portions were therefore invalidated to that extent.

## Legal Principles

- The state may regulate dangerous, intrusive, or potentially irreversible psychiatric procedures under its police power if the regulations are reasonably related to patient safety and welfare.
- Due process requires sufficiently definite statutory standards; vague criteria that fail to provide fair notice and permit arbitrary application are unconstitutional.
- Competent adults retain strong privacy interests in medical decision-making; compelled disclosure of sensitive treatment information to third parties requires substantial justification and cannot be imposed without adequate constitutional support.
- Heightened procedural protections are more readily justified for involuntary or incompetent patients than for voluntary, competent patients who provide informed consent.
- Severability is limited where unconstitutional provisions are interdependent with the statutory design such that excision would amount to judicial rewriting.

## Conclusion

The court largely sustained California’s ability to impose strict safeguards on psychosurgery and ECT, but it struck down mandatory relative-notification requirements and the vague “critical need” condition, and it limited severance where invalid provisions were embedded in the statutory structure.


Aden v. Younger, 57 Cal. App. 3d 662, 129 Cal. Rptr. 535 (Cal. Ct. App. 1976)