Allen Bodine Scott v. Dr. Ingre Rudolph Plante

Allen Bodine Scott (plaintiff) was committed to Trenton State Hospital in 1955 after being found incompetent to stand trial, by reason of insanity, for the murder of his grandmother. In 1968, the murder charge was dismissed on grounds of insanity, and Scott was returned to the hospital indefinitely. During 1955 and 1973, Scott filed several habeas petitions with the state court alleging lack of proper treatment, that he was being given medications without his or his guardian’s consent, that the conditions at the hospital were poor, and that his continued confinement violated his constitutional rights. In 1974, Dr. Saexinger, assistant medical director at Trenton, stated in an affidavit that Scott suffered from schizophrenia, was being treated with medication, and required further hospitalization. The affidavit did not indicate whether Scott consented to the medication, nor did the doctor state whether Scott would be a danger to himself or others upon release. The district court consolidated the five complaints filed against Dr. Ingre Rudolph Plante (defendant), chief executive officer at Trenton, and found that Scott might have a tort claim for being involuntarily given medication but that the hospital’s actions did not result in a constitutional violation. The district court granted summary judgment to Dr. Plante, and Scott appealed to the Third Circuit Court of Appeals.