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O'Connor v. Donaldson
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| O'Connor v. Donaldson | |
| Reference: 422 U.S. 563 | |
| Term: 1975 | |
| Important Dates | |
| Argued: January 15, 1975 Decided: June 26, 1975 | |
| Outcome | |
| United States Court of Appeals for the Fifth Circuit vacated | |
| Majority | |
| Potter Stewart • William Douglas • William Brennan • Byron White • Thurgood Marshall • Harry Blackmun • Lewis Powell • William Rehnquist | |
| Concurring | |
| Warren Burger | |
O'Connor v. Donaldson is a case decided on June 26, 1975, by the United States Supreme Court holding that states cannot commit an individual to a facility if they are not a danger to themselves or others. The case concerned the validity of a ruling by a trial court regarding a patient appealing his commitment to a state facility. The Supreme Court vacated the decision of the United States Court of Appeals for the Fifth Circuit.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that individuals cannot be committed to a facility against their will if they do not pose a threat and are capable of living without supervision. To read more about the impact of O'Connor v. Donaldson click here.
Background
Kenneth Donaldson was committed to a Florida state facility in January 1957 after being diagnosed with paranoid schizophrenia. Donaldson was told that he would be committed for a few weeks, but he remained in the state facility for approximately 15 years. Donaldson refused medication and treatment and was provided with minimal cognitive therapy. Donaldson filed suit against J.B. O'Connor, the clinical director of the facility, in February 1971 for depriving him of his right to liberty.
The jury ruled in favor of Donaldson, arguing that O'Connor had the authority to release Donaldson because he was not dangerous and failed to do so. O'Connor appealed the case to the United States Court of Appeals for the Fifth Circuit, arguing that the jury in the trial was prevented from finding that O'Connor had acted in good faith. The court of appeals rejected O'Connor's argument and affirmed the trial court's decision.[1][3]
Oral argument
Oral argument was held on January 15, 1975. The case was decided on June 26, 1975.[1]
Decision
The Supreme Court decided unanimously to vacate the decision of the United States Court of Appeals for the Fifth Circuit. Justice Potter Stewart delivered the opinion of the court. Chief Justice Warren Burger wrote a concurring opinion.[2]
Opinions
Opinion of the court
Justice Potter Stewart, writing for the court, argued that the state cannot confine individuals to a facility against their will if they do not pose a threat to themselves or others. As a result, Stewart contended that O'Connor was guilty of violating Donaldson's constitutional right to liberty.[2]
| “ | In short, a State cannot constitutionally confine, without more, a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends. Since the jury found, upon ample evidence, that O'Connor, as an agent of the State, knowingly did so confine Donaldson, it properly concluded that O'Connor violated Donaldson's constitutional right to freedom.[4] | ” |
| —Potter Stewart, majority opinion in O'Connor v. Donaldson[2] | ||
Stewart also posited that the trial court did not properly instruct the jury on the reliance on state law that O'Connor had claimed. He argued that the jury should have considered whether O'Connor knowingly and maliciously deprived Donaldson of his constitutional right to liberty. The Supreme Court ruled to remand the case to the United States Court of Appeals for the Fifth Circuit to reconsider O'Connor's sentence.[1][2]
| “ | The District Court did instruct the jury, without objection, that monetary damages could not be assessed against O'Connor if he had believed reasonably and in good faith that Donaldson's continued confinement was 'proper,' and that punitive damages could be awarded only if O'Connor had acted 'maliciously or wantonly or oppressively.' The Court of Appeals approved those instructions. But that court did not consider whether it was error for the trial judge to refuse the additional instruction concerning O'Connor's claimed reliance on state law as authorization for Donaldson's continued confinement. Further, neither the District Court nor the Court of Appeals acted with the benefit of this Court's most recent decision on the scope of the qualified immunity possessed by state officials under 42 U.S.C. § 1983. Wood v. Strickland, 420 U. S. 308.
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” |
| —Potter Stewart, majority opinion in O'Connor v. Donaldson[2] | ||
Concurring opinion
Chief Justice Warren Burger, in a concurring opinion, argued that the trial court should have considered Donaldson's repeated unsuccessful attempts for appeal in their decision of O'Connor's immunity. Burger agreed with the majority opinion regarding state confinement of non-dangerous individuals against their will.[2]
| “ | Perhaps more important to the issue of immunity is a factor referred to only obliquely in the Court's opinion. On numerous occasions during the period of his confinement Donaldson unsuccessfully sought release in the Florida courts; indeed, the last of these proceedings was terminated only a few months prior to the bringing of this action. See 234 So. 2d 114 (1969), cert. denied, 400 U.S. 869 (1970). Whatever the reasons for the state courts' repeated denials of relief, and regardless of whether they correctly resolved the issue tendered to them, petitioner and the other members of the medical staff at Florida State Hospital would surely have been justified in considering each such judicial decision as an approval of continued confinement and an independent intervening reason for continuing Donaldson's custody. Thus, this fact is inescapably related to the issue of immunity, and must be considered by the Court of Appeals on remand and, if a new trial on this issue is ordered, by the District Court.[4] | ” |
| —Warren Burger, concurring opinion in O'Connor v. Donaldson[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
O'Connor v. Donaldson established that states cannot commit an individual to a facility against their will if they do not pose a threat to themselves or others and are capable of living without supervision.[2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 Oyez, "O'Connor v. Donaldson," accessed August 4, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 Justia, "O'Connor v. Donaldson, 422 U.S. 563 (1975)," accessed August 4, 2022
- ↑ 3.0 3.1 LexisNexis, "O'Connor v. Donaldson - 422 U.S. 563, 95 S. Ct. 2486 (1975)," accessed August 4, 2022
- ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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