## Facts

- Mark Rivers, Florence Zatz, and Florence Grassi were involuntarily committed patients at Harlem Valley Psychiatric Center under New York Mental Hygiene Law orders finding them in need of involuntary care and treatment.
- Each patient refused proposed antipsychotic medication.
- Hospital staff overrode the refusals through an internal administrative process authorized by regulation (14 N.Y.C.R.R. § 27.8) and administered antipsychotic drugs involuntarily.
- Rivers and Zatz filed a declaratory judgment action asserting constitutional and common-law rights to refuse antipsychotic medication; Grassi filed an Article 78 proceeding raising similar claims.
- Trial courts dismissed both matters; the Appellate Division affirmed; the New York Court of Appeals consolidated the appeals.

## Issues

1. Whether involuntarily committed patients retain a fundamental state constitutional and common-law right to refuse antipsychotic medication.
2. Whether a judicial finding supporting involuntary commitment constitutes an implicit finding that the patient is incompetent to make treatment decisions.
3. Whether nonjudicial administrative procedures for authorizing forced antipsychotic medication satisfy due process, or whether judicial authorization is required absent an emergency.

## Decision

- The Court of Appeals reversed the Appellate Division.
- The court held that involuntarily committed patients retain a fundamental right, grounded in the New York Constitution’s due process clause and New York common law, to refuse antipsychotic medication.
- The court rejected the view that involuntary commitment alone establishes incompetence to make treatment decisions.
- The court held that, outside emergencies, the State may administer antipsychotic medication over a patient’s objection only after a judicial determination that the patient lacks capacity to make a reasoned treatment decision and that overriding the refusal is justified.
- The court concluded that physician-driven administrative review under 14 N.Y.C.R.R. § 27.8 did not provide constitutionally sufficient process for nonemergency forced medication decisions.

## Legal Principles

- Competent adults have a common-law and state due process liberty interest in bodily integrity and informed consent, including the right to refuse medical treatment.
- Involuntary civil commitment does not, by itself, eliminate the right to make medical decisions or constitute a blanket adjudication of treatment incapacity.
- Except in an emergency, forced administration of antipsychotic medication requires prior judicial authorization.
- The State bears the burden to prove incapacity by clear and convincing evidence in the judicial proceeding.
- If incapacity is found, the court must determine, under a substituted-judgment approach, whether medication should be authorized in light of the patient’s interests.

## Conclusion

New York’s highest court held that involuntarily committed psychiatric patients generally retain the right to refuse antipsychotic medication and that, absent an emergency, the State must obtain a court order—based on clear and convincing proof of decisional incapacity and a substituted-judgment determination—before forcibly medicating a patient.


Rivers v. Katz, 67 N.Y.2d 485, 504 N.Y.S.2d 74 (N.Y. 1986)