## Facts

- John E. Rennie, an involuntarily committed patient at a New Jersey state psychiatric hospital, challenged the non-emergency administration of antipsychotic medication over his objection.
- Rennie had a history of serious mental illness diagnoses and repeated hospitalizations, during which antipsychotic drugs were administered against his will.
- The challenged medications were characterized as powerful drugs carrying risks of serious and potentially permanent side effects.
- Rennie brought a federal civil-rights action on behalf of himself and a class of involuntarily committed patients in New Jersey’s state psychiatric hospitals.
- The district court issued a preliminary injunction recognizing a right to refuse antipsychotic medication and ordering a formal, independent premedication review process in non-emergencies.
- State officials appealed, arguing that New Jersey’s existing intra-hospital review procedures were constitutionally sufficient.

## Issues

1. Whether involuntarily committed patients have a constitutionally protected liberty interest in refusing antipsychotic medication, particularly given the drugs’ potentially severe side effects.
2. If a protected liberty interest exists, what procedural process is required before the state may medicate over a patient’s objection in non-emergency circumstances.
3. Whether New Jersey’s internal, professional review procedures satisfy due process, or whether a formal adversarial hearing is required.

## Decision

- The court held that involuntarily committed patients retain a constitutional right to refuse antipsychotic drugs that may have permanently disabling side effects.
- The right is qualified: the state may medicate without prior process in an emergency when the patient is a danger to self or others.
- In non-emergencies, some procedural protection is required before overriding refusal.
- The court modified the district court’s preliminary injunction by rejecting the requirement of a formal adversarial hearing.
- As modified, the injunction was affirmed because New Jersey’s internal, multi-level professional review process was constitutionally adequate.

## Legal Principles

- Involuntary commitment does not extinguish a patient’s Fourteenth Amendment liberty interest in bodily integrity and freedom from unwanted administration of antipsychotic medication with serious risks.
- A state may also create a protected liberty interest through statutes and institutional policies governing consent and treatment.
- The state may override a patient’s refusal in emergencies involving danger to self or others.
- In non-emergency situations, due process may be satisfied by a meaningful, professionally oriented administrative review process; due process does not necessarily require a judicial or quasi-judicial adversarial hearing.
- Decisions to medicate over objection must be subject to professional judgment and review beyond a single, unreviewed treating physician decision.

## Conclusion

The Third Circuit (en banc) recognized a qualified due process right of involuntarily committed patients to refuse antipsychotic medication, permitted emergency medication when the patient posed a danger, and held that New Jersey’s internal professional review procedures provided sufficient process in non-emergency situations, making a formal adversarial hearing unnecessary.


Rennie v. Klein, 653 F.2d 836 (3d Cir. 1981) (en banc)