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John Davis v. William Balson
United States District Court for the Northern District of Ohio
461 F. Supp. 842 (1978)
Facts
A class-action suit was filed by John Davis (plaintiff) against William Balson, superintendent of Lima State Hospital (LSH), on behalf of all individuals civilly or criminally committed at LSH on or after May 23, 1973. Davis sought injunctive and declaratory relief, arguing that LSH violated patients’ constitutional rights by forcing patients to work and not paying the federal minimum wage. While confined at LSH, patients were responsible for personal housekeeping and maintenance tasks. Additional work assignments were based solely on administrative convenience. Davis argued that the work was counter-therapeutic and that payment was therapeutically required to ensure that patients maintained a positive attitude towards their work. Patients who were employed worked an average of four to eight hours a day and were paid $10.00 to $15.00 a month. In addition, Davis argued that both civilly and criminally committed patients were entitled to due process prior to being moved to more restrictive environments or being sanctioned due to their behavior.
Rule of Law
Issue
Holding and Reasoning (Walinski, J.)
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