O'Connor v. Donaldson

Summary

In January 1957 Kenneth Donaldson was committed to the Florida State Hospital at Chattahoochee after his father sought a hearing before a Pinellas County judge, who found him mentally ill. He remained there against his will for nearly fifteen years. Dr. J. B. O'Connor was the hospital's superintendent for most of that time. Donaldson repeatedly asked for release, insisting that he was dangerous to no one, that he was not ill, and that in any case the hospital gave him no treatment. Offers to take him in, from a halfway house supported by a Minneapolis psychiatric clinic and four times from John Lembcke, a college classmate, were refused; O'Connor would release him only to his elderly parents. In February 1971 Donaldson sued O'Connor and other staff members for damages under the federal civil rights statute, 42 U.S.C. § 1983. He was released later that year, shortly after O'Connor retired. At trial the evidence showed that Donaldson had never been dangerous to himself or others, had supported himself for years before his commitment, and received only custodial care, which staff called milieu therapy. O'Connor's defense was that he had acted in good faith under a state law he believed authorized custodial confinement. The jury awarded $38,500, including punitive damages, and the Court of Appeals for the Fifth Circuit affirmed in a broad opinion recognizing a constitutional right to treatment for persons civilly committed. The question before the Supreme Court, as Justice Stewart framed it, was narrower: whether a State may confine a nondangerous person who is capable of surviving safely in freedom. Donaldson's side relied on the jury's findings and the right to liberty; O'Connor's side argued that he had followed state law in good faith and that the right to treatment announced by the appeals court had no basis in the Constitution. On 26 June 1975 a unanimous Court held that a finding of mental illness alone cannot justify indefinite custodial confinement. The State may not confine the harmless merely to give them a better standard of living than they would have outside, nor to spare the public from people whose ways are different. A State cannot constitutionally confine, without more, a nondangerous individual able to live safely in freedom alone or with the help of willing family or friends. The Court declined to decide whether a right to treatment exists, and it vacated the judgment and remanded so the appeals court could reconsider O'Connor's immunity defense under Wood v. Strickland (1975). Chief Justice Burger, concurring, emphasized that Donaldson had refused treatment offered to him and that state courts had repeatedly denied his petitions, and argued at length that history gives no support for limiting state confinement to cases where treatment is provided. The library text contains Stewart's full opinion and the first part of Burger's concurrence, without notes. Donaldson described his experience in Insanity Inside Out (1976). The decision contributed to tighter state commitment standards and was followed by Addington v. Texas (1979) and Youngberg v. Romeo (1982).

Top Lessons

• Liberty and the harmless

  The Court's holding rests on a simple principle: liberty is the rule, and confinement requires a justification. Illness alone, the State's benevolent wish to care for someone, or the public's discomfort does not suffice when a person is dangerous to no one and can live safely in freedom.

• Deciding no more than necessary

  The Fifth Circuit had announced a broad right to treatment. The Supreme Court deliberately decided a narrower question, leaving the larger issues for another day, and Burger wrote separately to stress that the broader holding had no approval. The case shows how courts control the reach of their own rulings.

• Custody and care

  The evidence described a large ward of sixty patients, no occupational training and treatment that staff admitted was a euphemism for confinement. Burger's history recalls that custodial care, in poorhouses, almshouses and later state hospitals, was long the main function of institutions. The case asks what an institution owes those it holds.

• Good faith and responsibility

  O'Connor argued that he had relied in good faith on state law. The Court did not excuse him but sent the question back to be decided under the standard that an official is liable if he knew or reasonably should have known that his actions violated constitutional rights. Students can weigh how personal responsibility applies to officials acting under law.

Verified Quotes

Medical Lens

O'Connor v. Donaldson is a landmark in the law and history of psychiatry: it established that mental illness alone does not justify involuntary confinement of a nondangerous person able to live safely in freedom, and it sits at the center of the debates over the right to treatment and deinstitutionalization. Stewart's opinion acknowledges the uncertainty of psychiatric diagnosis, and Burger's concurrence offers a short history of custodial care from almshouses to state hospitals. The record avoids clinical detail.

• Opinion of the Court, Part I, paragraph beginning: The evidence showed that Donaldson's confinement was a simple regime of enforced custodial care

  The trial evidence on custodial care, the term milieu therapy as staff used it, and a ward of sixty patients, a record of state-hospital conditions in the 1950s and 1960s.

• Opinion of the Court, Part II, paragraph beginning: A finding of "mental illness" alone cannot justify a State's locking a person up against his will

  The Court's holding that a diagnosis by itself does not justify confinement of the harmless, with a caution about whether the term mentally ill can be given reasonably precise content.

• Concurrence of Chief Justice Burger, Part II-A, paragraph beginning: That proposition is surely not descriptive of the power traditionally exercised by the States

  Burger's history of the care of the mentally ill from poorhouses and jails through the rise of state institutions, citing Albert Deutsch's The Mentally Ill in America.