## Facts

- Allen Bodine Scott, involuntarily confined at Trenton State Psychiatric Hospital’s maximum-security Vroom Building, challenged the conditions and nature of his long-term confinement and treatment.
- Scott proceeded through a guardian and brought civil rights claims under 42 U.S.C. § 1983 against hospital and state officials responsible for his confinement and care.
- Scott alleged unconstitutional conditions, lack of minimally adequate treatment, and decisions about confinement that were not professionally justified, including placement in a highly restrictive setting.
- The district court entered judgment for defendants on Scott’s claims, including claims seeking prospective (declaratory/injunctive) relief and damages.
- The Court of Appeals previously vacated the defense judgment on prospective relief and directed consideration of specific equitable relief, including whether Scott should be placed in a less restrictive setting; it also ordered a new trial on damages.
- The U.S. Supreme Court granted certiorari, vacated the Court of Appeals’ judgment, and remanded for reconsideration in light of Youngberg v. Romeo.
- On remand, the Court of Appeals reconsidered whether its earlier disposition remained proper under Youngberg’s due process framework.

## Issues

1. Whether an involuntarily confined psychiatric patient has a constitutionally protected right to adequate treatment and to professionally grounded consideration of less restrictive placement under the Fourteenth Amendment.
2. Whether, after Youngberg v. Romeo, a new trial is still required on claims for compensatory and punitive damages based on institutional conditions and treatment decisions.

## Decision

- The court vacated the judgment for defendants on Scott’s claims for prospective relief and remanded for consideration of specific equitable relief consistent with Youngberg.
- The court held that Youngberg supports recognizing Scott’s right to adequate treatment for purposes of prospective relief.
- The court held that Youngberg does not eliminate the need for further consideration of Scott’s claim for assignment to a less restrictive setting within the hospital.
- The court reaffirmed that a new trial is required on Scott’s compensatory and punitive damages claims, applying Youngberg’s governing standard.

## Legal Principles

- Involuntarily committed persons have substantive due process liberty interests that require constitutionally adequate conditions and care, assessed through the framework articulated in Youngberg.
- Liability turns on whether institutional decisions and conditions reflect professional judgment; a factfinder may impose liability if there is a significant departure from accepted professional judgment, practice, or standards.
- Courts must evaluate both the adequacy of treatment and the restrictiveness of placement through professionally grounded decision-making, with equitable relief available when constitutional minima are not met.
- Youngberg supplies the operative standard for adjudicating damages claims arising from treatment and conditions in psychiatric institutions and does not categorically bar such claims.

## Conclusion

The Third Circuit, applying Youngberg v. Romeo, vacated the defense judgment on prospective claims and remanded for specific equitable relief to secure adequate treatment and professionally considered less restrictive placement, and it reaffirmed the need for a new trial on compensatory and punitive damages under the professional-judgment/significant-departure standard.


Scott v. Plante, 691 F.2d 634 (3d Cir. 1982)