## Facts

- A certified class of persons civilly or criminally committed to Lima State Hospital (LSH) in Ohio (on or after May 23, 1973) sued LSH’s superintendent and other responsible state officials under 42 U.S.C. § 1983 for declaratory and injunctive relief and attorney’s fees.
- LSH operated as a state psychiatric facility housing both civilly and criminally committed patients.
- Patients were required to perform personal housekeeping and maintenance tasks; additional work assignments were made primarily for institutional convenience rather than individualized therapeutic criteria.
- Patients commonly worked about four to eight hours per day and received approximately $10–$15 per month, below the federal minimum wage.
- Plaintiffs contended the work program was counter-therapeutic, that meaningful pay was therapeutically necessary, and that compelled work at nominal pay violated constitutional and statutory protections (including the Thirteenth and Fourteenth Amendments).
- Plaintiffs also challenged the lack of procedural protections before (a) transfers to more restrictive settings and (b) imposition of disciplinary sanctions (including loss of privileges).

## Issues

1. Whether requiring confined psychiatric patients to perform institutional work for nominal compensation constitutes unconstitutional involuntary servitude or otherwise violates federal constitutional protections.
2. Whether LSH patients are entitled to procedural due process before transfers to substantially more restrictive conditions of confinement and before serious disciplinary sanctions.
3. What scope of equitable relief is appropriate to regulate a state hospital’s work program and internal transfer/discipline practices.

## Decision

- The court declined to hold that patient work at LSH must, as a general rule, be compensated at the federal minimum wage or that the work program was categorically unconstitutional.
- The court treated many work assignments—particularly housekeeping and institutional-maintenance tasks—as part of lawful confinement and institutional operation rather than a standard employer–employee relationship.
- The court required that work assignments be justified by legitimate therapeutic or institutional needs and not imposed in an arbitrary, punitive, or exploitative manner.
- The court held that transfers to substantially more restrictive environments and serious sanctions may implicate protected liberty interests and therefore warrant some procedural protections.
- The court did not require full adversarial hearings for routine or lesser institutional adjustments, giving deference to professional and administrative judgment in day-to-day operations.

## Legal Principles

- Compulsory labor connected to lawful confinement, when reasonably related to institutional maintenance, rehabilitation, treatment, or security, does not necessarily constitute involuntary servitude under the Thirteenth Amendment.
- Confinement in a mental-health institution does not automatically create an employment relationship triggering minimum-wage treatment for patient labor; the nature and purpose of the work and the institution’s functions are central to the analysis.
- Due process protections may be required when institutional action imposes a significant increase in restrictiveness or a serious deprivation, but the required procedures may be limited and calibrated to institutional needs and safety.
- Federal equitable relief may correct unconstitutional institutional practices while avoiding detailed judicial control over ordinary clinical and administrative decisions, particularly where qualified professionals exercise considered judgment.

## Conclusion

The court rejected a blanket rule that confined psychiatric patients performing institutional work are entitled to minimum-wage compensation and instead focused on whether work assignments served legitimate institutional or therapeutic purposes. It also required limited procedural protections for major increases in restrictiveness or serious sanctions, while deferring to professional judgment for routine internal decisions.


Davis v. Balson, 461 F. Supp. 842 (N.D. Ohio 1978)