## Facts

- Pennhurst State School and Hospital was a Pennsylvania-run institution housing about 1,200 individuals with intellectual disabilities.
- Residents, through guardians and advocacy groups, filed a federal class action alleging that Pennhurst conditions and treatment were dangerous, unsanitary, and inhumane, including excessive restraint, isolation, unnecessary medication, lack of habilitation services, and inadequate supervision.
- Plaintiffs alleged violations of federal constitutional protections, federal statutes addressing services for persons with developmental disabilities, and Pennsylvania’s Mental Health and Mental Retardation Act of 1966 (MH/MR Act) and related state law.
- After trial, the district court found systemic unsafe and degrading conditions and concluded residents were entitled to habilitation, protection from harm, and placement in the least restrictive environment.
- The district court entered extensive prospective relief after the parties failed to agree on a plan, including barring new admissions, requiring individualized plans, ordering development of community living arrangements, and appointing a special master; the defendants appealed.

## Issues

1. Whether conditions and treatment at Pennhurst violated residents’ federal constitutional rights, including substantive due process protections against unsafe and harmful institutional confinement.
2. Whether federal developmental-disability statutes created enforceable rights to appropriate treatment or habilitation and placement in the least restrictive environment.
3. Whether Pennsylvania’s MH/MR Act and state regulations required least-restrictive care and adequate habilitation, and whether those obligations were enforceable in federal court.
4. Whether the district court’s structural injunction (including deinstitutionalization measures and operational mandates) exceeded permissible equitable relief.

## Decision

- The en banc Third Circuit largely affirmed the district court’s liability conclusions that Pennhurst residents were entitled to adequate habilitation and protection from harmful institutional conditions.
- The court agreed that Pennsylvania’s MH/MR Act required a “least restrictive environment” approach for care of persons with intellectual disabilities and supported a right to adequate habilitation.
- The court upheld, with some modification, the broad prospective injunction requiring development of community living arrangements, individualized planning, and limits on continued institutionalization at Pennhurst (including cessation of new admissions).
- The court rejected the argument that the Eleventh Amendment barred consideration and enforcement of the pendent state-law obligations as part of prospective relief against state officials.

## Legal Principles

- Individuals confined in a state institution may possess substantive due process protections requiring minimally adequate habilitation and reasonable safety, including freedom from conditions that cause physical or psychological harm.
- State statutory schemes governing disability services can be construed to impose affirmative obligations on the state to provide habilitation in the least restrictive setting, including community-based alternatives when feasible.
- Federal courts may issue structural, forward-looking injunctions to remedy systemic rights violations in state institutions, including orders requiring individualized planning, oversight mechanisms, and reconfiguration of service delivery systems.
- In this decision, prospective injunctive relief against state officials was treated as available even when partly grounded in pendent state-law duties, alongside federal claims.

## Conclusion

The Third Circuit sustained major findings that Pennhurst residents were entitled to habilitation and safety and approved expansive injunctive relief directing least-restrictive, community-based placements and institutional reform, relying on a combination of federal constitutional principles and Pennsylvania’s MH/MR Act.


Halderman v. Pennhurst State Sch. & Hosp., 612 F.2d 84 (3d Cir. 1979) (en banc)