## Facts

- The plaintiff class consisted of patients in five New Jersey state psychiatric hospitals, most involuntarily committed and many treated with antipsychotic (psychotropic) drugs.
- John E. Rennie, an involuntarily committed but not adjudicated incompetent patient at Ancora Psychiatric Hospital, objected to antipsychotic medication due to serious side effects and served as the initial catalyst for class-wide relief.
- Hospital conditions included chronic understaffing and heavy patient loads, contributing to widespread reliance on medication.
- New Jersey had written procedures addressing forced medication, but the court found them limited in practice, inconsistently applied, and poorly documented.
- The court found systemic failures to record medication refusals, track and record severe side effects, and inform patients of any right to refuse.
- Evidence indicated that antipsychotic drugs were often administered over objection for behavioral control or institutional convenience rather than individualized medical necessity.

## Issues

1. Whether involuntarily committed but competent patients have a constitutional liberty interest in refusing antipsychotic medication in non-emergency circumstances.
2. Whether existing institutional procedures for overriding refusal satisfied due process, or whether additional safeguards were constitutionally required.
3. Whether plaintiffs met the requirements for a preliminary injunction based on likelihood of success and irreparable harm.

## Decision

- The court held that involuntarily committed patients who are not adjudicated incompetent have a qualified constitutional right, grounded in due process, to refuse antipsychotic medication in certain circumstances.
- The court ruled that the state may medicate over a competent patient’s objection only in emergencies involving danger to self or others, or in non-emergencies after specified procedural safeguards.
- The court granted a class-wide preliminary injunction imposing system-wide requirements governing non-emergency forced medication decisions and documentation of emergency administrations.
- The court found plaintiffs showed a likelihood of success on the merits and irreparable harm from unwanted administration of drugs with serious and potentially lasting effects.

## Legal Principles

- Forced administration of antipsychotic medication implicates a protected liberty interest in bodily integrity and autonomy under the Due Process Clause.
- The right to refuse psychotropic medication is qualified and may be overridden to address emergency danger or to further legitimate state interests through procedures that reduce the risk of arbitrary decisions.
- Due process in non-emergency forced-medication decisions requires meaningful safeguards beyond unilateral treating-physician choice, including review by a neutral decision-maker, patient notice and opportunity to object, documentation, and periodic review.
- Injunctive relief is appropriate where unconstitutional forced medication presents non-compensable harm and institutional practices create a substantial risk of medication for non-therapeutic reasons.

## Conclusion

The district court granted preliminary, class-wide injunctive relief recognizing a qualified due process right of competent involuntarily committed patients to refuse antipsychotic medication and restricting non-emergency forced medication to situations preceded by structured procedural protections, while permitting immediate medication in documented emergencies.


Rennie v. Klein (Rennie II), 476 F. Supp. 1294 (D.N.J. 1979)