Donaldson v. O'Connor

493 F.2d 507 (1974)

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Donaldson v. O'Connor

United States Court of Appeals for the Fifth Circuit
493 F.2d 507 (1974)

Facts

Kenneth Donaldson (defendant) suffered from paranoid schizophrenia and was involuntarily civilly committed to a Florida state hospital where Dr. J.B. O’Connor (plaintiff) was the superintendent. While superintendent, Dr. O’Connor was authorized to release nondangerous patients who could care for and protect themselves or who had responsible family or friends to do so. Donaldson was considered a nondangerous patient and had petitioned Dr. O’Connor for his release on several occasions because in his 15-year confinement, Donaldson received little treatment, at times simply being confined in a room with dozens of patients with various mental illnesses and reasons for confinement. Following a trial, a jury found that Dr. O’Connor had violated Donaldson’s constitutional right to liberty by involuntarily confining him without providing adequate treatment. Dr. O’Connor appealed the jury’s verdict, arguing, as one basis, that provision of adequate treatment cannot be judicially ascertained or managed.

Rule of Law

Issue

Holding and Reasoning (Wisdom, J.)

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