## 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 repeated hospitalizations beginning in 1973 and was diagnosed with serious mental illness marked by delusions, suicidal ideation, and episodes of dangerous behavior.
- Hospital staff administered a long-acting injectable antipsychotic to address worsening behavior and to aid treatment compliance; his condition improved after medication.
- Rennie brought a class action seeking to enjoin forced administration of psychotropic drugs to involuntarily committed patients who refused them outside emergencies.
- The district court recognized a constitutional liberty interest in refusing treatment and imposed an injunction requiring safeguards beyond the state hospital system’s internal policy.
- The Third Circuit previously recognized a constitutional right to refuse treatment subject to a “professional judgment” limitation; after the Supreme Court’s decision in *Youngberg v. Romeo*, the Supreme Court vacated and remanded for reconsideration under that standard.
- On remand, the Third Circuit evaluated whether New Jersey’s internal policy (Administrative Bulletin 78-3) provided constitutionally sufficient protections for medication-over-objection decisions.

## Issues

1. Whether involuntarily committed patients have a Fourteenth Amendment liberty interest in refusing antipsychotic medication in non-emergency situations.
2. Whether *Youngberg* requires courts to uphold forced-medication decisions that reflect qualified professional judgment, absent a substantial departure from accepted professional standards.
3. Whether New Jersey’s internal review procedures for medicating refusing patients provide sufficient due process protection, or whether additional court-like procedures are constitutionally required.

## Decision

- The Third Circuit reaffirmed that involuntarily committed patients possess a constitutionally protected, but qualified, liberty interest in refusing antipsychotic medication.
- The court applied *Youngberg*’s “professional judgment” framework to forced-medication decisions.
- The court held New Jersey’s Administrative Bulletin 78-3 procedures were constitutionally adequate to protect the liberty interest in non-emergency situations.
- The court modified the district court’s injunction to align with the state’s professional-review process rather than the more demanding judicially imposed regimen.

## Legal Principles

- Involuntarily committed persons retain a substantive due process liberty interest in bodily integrity and in avoiding unwanted antipsychotic medication.
- The right to refuse psychotropic medication is qualified and may yield to legitimate treatment and safety interests when medication is supported by professional medical decision-making.
- Under *Youngberg*, courts defer to decisions of qualified professionals unless the decision represents a substantial departure from accepted professional judgment, practice, or standards.
- Due process in this setting may be satisfied by structured internal clinical review (including documentation and second-opinion review) rather than formal judicial or quasi-judicial hearings.
- Emergency circumstances permit immediate medication to prevent imminent serious harm without prior completion of non-emergency review steps, but non-emergency medication over objection requires compliance with the professional-review procedures.

## Conclusion

The Third Circuit recognized a qualified constitutional right of involuntarily committed patients to refuse antipsychotic drugs, held that *Youngberg* requires deference to qualified professional judgment, and concluded that New Jersey’s internal multi-professional review procedures provided sufficient constitutional protection, warranting modification of the district court’s more rigorous injunction.


Rennie v. Klein, 720 F.2d 266 (3d Cir. 1983)