## Facts

- A class action was brought on behalf of thousands of patients involuntarily confined in Alabama state mental institutions, including Bryce Hospital and Searcy Hospital.
- The patients were civilly committed for mental health treatment purposes, not incarcerated following criminal convictions.
- The court previously held that involuntarily committed patients have a constitutional right to treatment offering a realistic opportunity to improve or be cured and found the existing care constitutionally deficient.
- After allowing time for improvements, the court determined the institutions remained overcrowded and understaffed, making meaningful treatment effectively unavailable.
- The court found unsafe and degrading conditions, including physical hazards, inadequate privacy, poorly trained staff, and routine use of nontherapeutic, uncompensated patient labor.
- The court required the parties and amici to propose concrete minimum standards for constitutionally adequate care and treatment.

## Issues

1. What minimum constitutional standards of care and treatment are required for patients involuntarily civilly committed to state mental institutions.
2. Whether conditions and treatment at Bryce and Searcy met those minimum standards as of 1972, and, if not, what specific remedial requirements should be ordered.
3. Whether the state could justify continued noncompliance with constitutional requirements by citing insufficient operating funds.

## Decision

- The court reaffirmed that involuntarily committed patients have a constitutional right to adequate treatment grounded in due process.
- The court found ongoing constitutional violations at Bryce and Searcy because patients were not provided:
  - a humane psychological and physical environment,
  - qualified staff in sufficient numbers, and
  - individualized treatment plans offering a reasonable opportunity for improvement.
- The court ordered implementation of detailed minimum treatment requirements (the “Wyatt standards”) as constitutional floors, not ceilings.
- The court rejected lack of operating funds as a defense to unconstitutional conditions and ordered compliance notwithstanding fiscal constraints.
- The court retained jurisdiction, required progress reporting, and contemplated further structural measures to ensure implementation.

## Legal Principles

- Civil commitment is constitutionally justified only if the state provides treatment or habilitation; custodial confinement without adequate care violates substantive due process.
- Constitutionally adequate institutional care requires, at minimum:
  - humane and safe living conditions,
  - sufficient numbers of qualified staff to deliver treatment, and
  - individualized treatment planning geared to providing a reasonable chance of improvement.
- Courts may order detailed operational standards (including staffing, environment, programming, and recordkeeping) to make the right to treatment enforceable.
- Fiscal limitations do not excuse failure to meet constitutional minimums; constitutional obligations are mandatory.

## Conclusion

The court held that Alabama’s mental institutions failed to provide the minimum care required by due process for involuntarily committed patients and imposed enforceable, detailed standards for humane conditions, adequate staffing, and individualized treatment, ordering compliance regardless of funding constraints under continuing judicial supervision.


Wyatt v. Stickney, 344 F. Supp. 373 (M.D. Ala. 1972)