## Facts

- Kenneth Donaldson was involuntarily civilly committed to Florida State Hospital in January 1957 and diagnosed as a paranoid schizophrenic.
- He remained confined for about 14½ years.
- During confinement, he received little or no psychiatric care or meaningful individualized treatment and was often housed in overcrowded conditions.
- Evidence supported that Donaldson was not dangerous to himself or others.
- Evidence supported that he could survive safely in freedom, either independently or with help from willing and responsible family or friends.
- Donaldson repeatedly requested discharge; friends and family repeatedly offered outside care, but hospital officials refused to release him.
- Donaldson brought a 42 U.S.C. § 1983 action against hospital officials alleging unconstitutional confinement without treatment.

## Issues

1. Whether the Fourteenth Amendment guarantees involuntarily civilly committed mental patients a judicially enforceable right to treatment.
2. Whether confining a nondangerous person who can live safely in the community, while providing little or no treatment, violates due process and supports § 1983 damages against responsible officials.
3. Whether the evidence and jury instructions were sufficient to sustain the verdict and damages awards.

## Decision

- The Fifth Circuit affirmed the district court judgment for Donaldson.
- The court held that the Fourteenth Amendment guarantees involuntarily civilly committed mental patients a right to treatment.
- The court concluded the evidence permitted the jury to find that Donaldson was confined for years with little or no treatment despite being nondangerous and able to live safely outside the institution.
- The court rejected the argument that treatment adequacy is nonjusticiable, holding that constitutional minimums are enforceable and the proof here met that threshold.
- The court upheld the jury’s damages awards against O’Connor and Gumanis.

## Legal Principles

- Civil commitment is constitutionally justified only by legitimate state interests such as protection of the public (dangerousness) or parens patriae care for those unable to care for themselves.
- When the state confines a person for therapeutic reasons, due process requires minimally adequate treatment directed toward improvement; otherwise continued confinement becomes arbitrary.
- If a committed person is not dangerous and can survive safely in freedom (alone or with responsible assistance), prolonged confinement without meaningful treatment lacks constitutional justification.
- Courts may enforce constitutional minima regarding treatment and confinement, even while generally deferring to medical judgment on clinical details.

## Conclusion

The Fifth Circuit held that due process requires the state to provide minimally adequate treatment to involuntarily committed mental patients and affirmed § 1983 damages where officials kept a nondangerous man confined for more than fourteen years with little or no treatment despite evidence he could live safely outside the hospital.


Donaldson v. O’Connor, 493 F.2d 507 (5th Cir. 1974)