RESEARCH and find out what is was like for him in the institution like what conditions did he have to live in, how were his rights violated, did he have to do work, did he received any t
RESEARCH and find out what is was like for him in the institution like what conditions did he have to live in, how were his rights violated, did he have to do work, did he received any treatment to help him, was he abused and any other information that pertains to this part of the case. ( PPT)
O’Connor v Donaldson
A Miscarriage of Justice
F
2
August 1971 – U.S. District Court.
Argued in Supreme Court – January 15, 1975
Decided in Supreme Court – June 26, 1975.
People with mental illness should not be imprisoned like criminals, but be
given a chance to connect and live in society just like any other individual.
With proper care and treatment, they can live happy and successful lives,
just like you and I.
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,
O’connor vs Donaldson
SSMH 215
Illyana Whiteley, Khalee Montesi, Raymond Power, Irene Shim, Ashlyn Sauvageau
Facts of the Case
William Kenneth Donaldson was born on may 22nd 1908. He lived a normal life, finished college and got married having 3 children. In 1943, Donaldson was committed for 4 months in new York after having a mental breakdown. He felt he was harassed, and slandered, and that people tampered with his mail and put medication in his food. In 1953 he changed his name to Kenneth mccullough, and in 1955 to Kenneth Donaldson in attempt to divert his “persecutors” . Later on He divorced, but was able to maintain several jobs. In 1956, he was admitted and treated for paranoid schizophrenia. He was shortly released at which point he went to see his parents in Florida.
Facts of the Case
On January 3, 1957, Kenneth Donaldson’s father asked for a sanity hearing, due to believing that his son was suffering from delusions. following a brief hearing before a county judge, Twelve days later, he was admitted to Florida State Hospital and soon thereafter was diagnosed as a paranoid schizophrenic. The committing judge told Donaldson that he was being sent to the hospital for “a few weeks” for “care, maintenance and treatment”. Donaldson felt he never had a chance, due to not being represented by a lawyer at the commitment hearing.
Facts of the Case
At the time of admittance, the super intendent of the florida state hospital was a man named dr. J.B. o’connor who was the primary caretaker of Donaldson. O’connot admitted and deemed that Donaldson was no danger to himself or anyone else, but placed him in a ward with dangerous criminals, that was severely over populated and understaffed, with no psychiatrists or counselors.
Facts of the Case
In 1963 a program called helping hands, which is a halfway house for mental patients reached out to o’connor asking him to release Donaldson to their care. They supplied a supporting letter from the Minneapolis clinic of psychiatry and neurology as evidence that they were a “good clinic”, and could help Donaldson. O’connor denied the request stating that that he could only be released to his parents. At that time, Donaldson was 55 years old, and o’connor made it clear that his parents were unfit and too old for them to assume responsibility for donaldson. Between 1964 and 1968, donaldson was rejected release 4 more times. One rejection was to a college classmate, and long time friend of the family John Lembcke who was proved worthy to take responsibility for donaldson.
Facts of the case
Donaldson’s confinement was simple enforced custodial care. There was no program designed to help him alleviate or cure his “sickness”. O’connor described his “treatment” at the hospital as “milieu therapy”. Staff witnesses confessed that the “milieu therapy” consisted of donaldson being kept in a large room that was home to 60 patients, many of them being criminally committed. Donaldson was offered shock therapy-which he denied. Donaldson-who had good behavior, requested on several occasions for grounds privileges, occupational training or opportunities to talk to o’connor about his case. Every single time, he was denied.
Facts of the case
Donaldson was acknowledged many times to have full ability to be able to function and be a part of society outside of the hospital. When he was released after 14 and a half years in confinement, he did just that. He got a job immediately in hotel administration, wrote a book about his story, and continued to live his life with limited issues. He never returned to a mental health hospital again.
the case
In February 1971, Donaldson charged O’Connor and other members of the hospital’s staff under 42 U.S.C. 1983 with intentionally and maliciously depriving him of his constitutional right to liberty. Evidence at trial showed that the staff had the power to release a mentally ill, committed patient if he was not dangerous to himself or others, but that the staff did not exercise this power.
the case
O’connor contended that he should not be personally made responsible for damages because he believed that his decisions were made in “good Faith”. He argued that he was acting pursuant to state law, which he believed authorized confinement of the mentally ill even when their release would not compromise their safety or constitute a danger to others, and that he could not reasonably have been expected to know that the state law as he understood it was constitutionally invalid.
O’CONNOR ALSO ARUGED THAT HE TRULY BELIEVED THAT DONALDSON COULD NOT ADJUST TO THE OUTSIDE WORLD, BUT COULDN’T RECALL THE BASIS FOR HIS CONCLUSION OF “GOOD FAITH”
The case
The jury found for donaldson and awarded compensatory and punitive damages against o’connor and the other HOSPITAL STAFF CHARGED. The court of appeals on broad Fourteenth Amendment grounds, affirmed the District Court's ensuing judgment entered on the verdict. Held:
1. A State cannot constitutionally confine, without more, a non-dangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends, and since the jury found, upon ample evidence, that petitioner did so confine respondent, it properly concluded that petitioner had violated respondent's right to liberty.
2. Since the Court of Appeals did not consider whether the trial judge erred in refusing to give an instruction requested by petitioner concerning his claimed reliance on state law as authorization for respondent's continued confinement, and since neither court below had the benefit of this Court's decision in Wood v. Strickland( 420 U.s. 308), on the scope of a state official's qualified immunity under 42 U.S.C. 1983, the case is vacated and [422 U.S. 563, 564] remanded for consideration of petitioner's liability vel non for monetary damages for violating respondent's constitutional right.
The CAse
O’Connor appealed his case separately, and the United States Court of Appeals for the Fifth Circuit, affirmed the jury’s verdict. The court rejected O’Connor’s argument that the trial court improperly barred the jury from finding that O’Connor acted in good faith. The jury instruction was valid because it explicitly stated that the defendants’ reasonable belief that Donaldson’s confinement was proper would preclude damages. Any reliance on state law would fall under this consideration of O'Connor's good faith intentions.
Did the Fifth Circuit properly consider the trial court's failure to instruct the jury on O’Connor’s claimed reliance on state law?
NO
the case
In a unanimous decision written by Justice Potter Stewart, the Court vacated the judgment of the Fifth Circuit. While the trial court properly instructed the jury on the relevance of O’Connor’s good faith intentions, Justice Stewart held that the Fifth Circuit must determine if the trial court properly instructed the jury on O’Connor’s reliance on state law. Justice Stewart acknowledged that the state cannot constitutionally confine a non-dangerous, mentally ill person capable of living outside of a mental health facility. He noted, however, that neither the trial court nor the Fifth Circuit acted with knowledge of the Court’s most recent decision on the scope of state officials’ qualified immunity, Wood v. Strickland. Under that decision, the relevant question for the jury was whether O’Connor knew his actions would deprive Donaldson of his constitutional rights, or whether he maliciously deprived him of his constitutional rights. The Court remanded the case back to the Fifth Circuit to be reconsidered with this test in mind.
Chief Justice Warren Burger concurred. He argued that the Fifth Circuit should consider Donaldson’s consistent refusal of medical treatment to be taken into account in considering the respondent’s good faith defense. Chief Justice Burger also would have ordered the Fifth Circuit to consider the hospital staff’s potential reliance on Donaldson’s repeated unsuccessful attempts to seek release through the Florida court system.
Kenneth Donaldson after release
References
http://drs.library.yale.edu/HLTransformer/HLTransServlet?stylename=yul.ead2002.xhtml.xsl&pid=mssa:ms.1677&clear-stylesheet-cache=yes
https://www.oyez.org/cases/1974/74-8
http://caselaw.findlaw.com/us-supreme-court/422/563.html
The End
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