## Facts

- John E. Rennie was an involuntarily committed patient at Ancora Psychiatric Hospital, a New Jersey state facility, and was found competent.
- Rennie had repeated hospitalizations beginning in 1973, with diagnoses including paranoid schizophrenia and manic-depressive psychosis, and a history of medication noncompliance after release.
- During his twelfth hospitalization (beginning August 10, 1976), his condition deteriorated in December 1977; staff believed he posed a danger to himself, other patients, and staff.
- The treatment team administered Prolixin decanoate, a long-acting antipsychotic injection, citing safety concerns and treatment effectiveness; Rennie’s condition improved after the regimen began.
- Rennie objected to Prolixin due to risks of serious side effects, including potentially irreversible movement disorders, and offered to take other medications instead.
- Rennie sued state officials and hospital administrators under 42 U.S.C. § 1983, asserting (as narrowed for the preliminary-injunction hearing) a right to refuse antipsychotic medication in non-emergency circumstances.
- Pending the preliminary-injunction decision, the parties agreed Rennie would not be medicated beyond a defined “maintenance dosage” except in emergencies.
- After extensive evidentiary hearings, the court ruled on Rennie’s motion for a preliminary injunction.

## Issues

1. Whether a competent, involuntarily committed psychiatric patient has a constitutional liberty interest in refusing antipsychotic medication.
2. If such an interest exists, when the state may override refusal based on safety, institutional order, and treatment needs.
3. What substantive and procedural safeguards are required before administering antipsychotic drugs over a patient’s objection in non-emergency situations at a state hospital.
4. Whether preliminary-injunction factors warranted an order limiting forced medication to “clear emergencies” only.

## Decision

- The court recognized that forced administration of antipsychotic drugs implicates a substantial liberty interest in bodily integrity protected by the Fourteenth Amendment.
- The court held the interest is qualified, not absolute, and may be overridden based on danger to self or others and legitimate institutional safety and treatment responsibilities, if governed by appropriate safeguards.
- The court denied Rennie’s request for a sweeping preliminary injunction barring non-emergency forced medication.
- Instead, the court ordered injunctive relief establishing a structured framework for professional judgment and internal review for non-emergency medication decisions.

## Legal Principles

- Involuntarily committed persons retain a constitutionally protected liberty interest in avoiding unwanted administration of antipsychotic medication, given the drugs’ intrusive nature and risk of serious, potentially permanent side effects.
- The state may override a competent patient’s refusal when necessary for safety, institutional order, or effective treatment, so long as the decision is grounded in professional judgment rather than unfettered discretion.
- Due process requires safeguards for non-emergency forced medication, including meaningful review mechanisms within the institution to protect the patient’s liberty interest while allowing medically justified treatment.
- On a preliminary-injunction request, a court may decline broad prohibitory relief where the requested rule (emergency-only medication) is not shown likely to prevail, yet still craft narrower injunctive protections to reduce irreparable harm.

## Conclusion

The court treated forced antipsychotic medication as a serious interference with liberty and bodily integrity, but concluded that a competent involuntarily committed patient’s right to refuse is qualified and may yield to professionally justified safety and treatment needs when accompanied by procedural protections; accordingly, it denied an emergency-only injunction and imposed a safeguards-based framework for non-emergency decisions.


Rennie v. Klein, 462 F. Supp. 1131 (D.N.J. 1978)