## Facts

- St. Elizabeths Hospital was a federally administered psychiatric hospital serving primarily District of Columbia residents civilly committed under the District of Columbia Hospitalization of the Mentally Ill Act of 1964.
- William Dixon and a certified class were District residents confined at St. Elizabeths pursuant to the 1964 Act.
- Hospital clinical staff concluded that a substantial portion of inpatients (about 43%) did not require continued hospitalization and instead needed care in alternative facilities such as nursing homes, foster homes, personal care homes, or halfway houses.
- Plaintiffs alleged they were unnecessarily kept at St. Elizabeths because federal and District officials failed to provide appropriate community-based placements.
- Plaintiffs sought declaratory relief that the 1964 Act’s treatment mandate includes placement outside St. Elizabeths when consistent with the Act’s rehabilitative purpose, and that federal and District authorities jointly had breached duties to provide those placements.
- The court addressed cross-motions for summary judgment and limited its ruling to statutory grounds rather than constitutional claims.

## Issues

1. Whether the 1964 Act’s right to “care and treatment” requires placement in less restrictive, community-based facilities when clinically appropriate, rather than continued hospitalization due solely to a lack of available alternatives.
2. Whether responsibility to provide such alternative placements rests with the federal government, the District of Columbia, or both jointly.

## Decision

- The court granted plaintiffs’ motion for partial summary judgment on the statutory interpretation questions and denied defendants’ contrary positions.
- The court held the 1964 Act requires treatment that includes placement in suitable, less restrictive alternatives when clinically appropriate.
- The court held the federal government and the District of Columbia share a joint obligation to provide and ensure the availability of appropriate community-based alternatives for eligible patients.
- The court resolved the case on statutory grounds and did not reach constitutional questions.

## Legal Principles

- A civilly committed patient’s statutory right to treatment under the 1964 Act includes treatment in the least restrictive setting consistent with clinical needs, including community placement when appropriate.
- Continued confinement in a custodial hospital setting is inconsistent with the statute when clinical judgment supports alternative placement and the only barrier is governmental failure to provide alternatives.
- Where statutory structure and funding/administration reflect shared responsibility, both sovereigns may bear a legally enforceable joint duty to implement the statute’s treatment mandate.
- Courts may interpret a statute to provide effective relief and thereby avoid deciding constitutional questions when statutory grounds suffice.

## Conclusion

The court declared that the 1964 Act’s treatment mandate requires clinically appropriate placement in less restrictive, community-based settings and that both federal and District of Columbia officials are jointly responsible for making such alternatives available, so patients may not be kept hospitalized solely because community placements have not been provided.


Dixon v. Weinberger, 405 F. Supp. 974 (D.D.C. 1975)