## Facts

- Allen Bodine Scott was a long-term patient at Trenton State Hospital, a New Jersey psychiatric facility used for persons charged with crimes but found incompetent to stand trial or acquitted by reason of insanity.
- Scott alleged he had been confined since 1955 and that criminal charges were dismissed on insanity grounds in 1968, yet he remained hospitalized.
- Scott brought multiple pro se actions under 42 U.S.C. § 1983 against state hospital and New Jersey officials, seeking declaratory and injunctive relief and damages.
- He alleged his continued confinement after dismissal of charges violated constitutional rights and lacked adequate justification or procedures.
- He alleged he was forcibly administered drugs and other treatment against his will and without consent of a family member or guardian.
- He alleged substandard conditions and failure to provide rehabilitation, discharge, or transfer to a civil hospital despite the dismissal of charges.
- The record included an affidavit from a hospital official stating Scott had schizophrenia, was medicated, and required further hospitalization, without addressing consent, dangerousness, or the legal basis for continued detention and treatment.
- The district court consolidated five complaints and granted summary judgment for defendants, reasoning the allegations at most stated state-law tort claims rather than federal constitutional violations.

## Issues

1. Whether continued confinement in a state psychiatric hospital after dismissal of criminal charges could violate the Fourteenth Amendment absent adequate substantive justification and procedures.
2. Whether involuntary administration of psychiatric drugs and other treatment, without consent or sufficient safeguards, can constitute a deprivation of liberty without due process actionable under § 1983.
3. Whether allegations of inadequate care, lack of rehabilitation, and failure to pursue discharge or transfer can state constitutional claims by an involuntarily confined patient.
4. Whether summary judgment was proper given the limited record and the obligation to construe pro se pleadings liberally.

## Decision

- The Third Circuit reversed (or vacated in relevant part) the summary judgments dismissing Scott’s federal constitutional claims.
- The court held the district court erred by treating forced medication and continued confinement as merely potential torts; the allegations implicated protected liberty interests under the Due Process Clause.
- The court concluded the existing record did not eliminate genuine disputes of material fact regarding justification and procedures for confinement and treatment.
- The case was remanded for further proceedings to develop the factual record and apply appropriate constitutional standards.

## Legal Principles

- Involuntary psychiatric confinement must be supported by constitutionally sufficient substantive grounds and procedures; prior involvement in the criminal process does not by itself justify indefinite hospitalization.
- Nonconsensual psychiatric drugging and similar bodily intrusions implicate a protected liberty interest in bodily integrity and personal security and may require substantive justification and procedural protections.
- Conduct that could be actionable as a state-law tort may also constitute a federal due process deprivation; the availability of tort remedies does not foreclose § 1983 relief.
- Involuntarily confined persons retain constitutional protections concerning the purposes, duration, and conditions of confinement, including claims tied to arbitrary detention and inadequate treatment.
- Pro se complaints must be construed liberally, and summary judgment is improper where the record is too undeveloped to resolve material constitutional questions.

## Conclusion

The Third Circuit held that allegations of continued post-dismissal psychiatric confinement, forced medication, and lack of adequate treatment could amount to Fourteenth Amendment due process violations actionable under § 1983, and it remanded because summary judgment was premature on the limited record.


Scott v. Plante, 532 F.2d 939 (3d Cir. 1976)