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John E. Rennie v. Ann Klein (Rennie III)

653 F.2d 836 (1981)

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John E. Rennie v. Ann Klein (Rennie III)

United States Court of Appeals for the Third Circuit

653 F.2d 836 (1981)

Facts

A class-action suit seeking injunctive relief was filed by John E. Rennie (plaintiff), on behalf of patients committed at five New Jersey mental hospitals. Rennie argued that administering antipsychotic drugs without patient consent was a constitutional violation. The district court granted a preliminary injunction against Ann Klein (defendant), commissioner of the Department of Human Services (the DHS), ordering the DHS to implement additional safeguards prior to forcibly medicating patients. Klein appealed the district court’s order to the Third Circuit Court of Appeals. Klein argued that the DHS’s internal procedures were adequate because the procedures required that the treating physician explain the need, side effects, risks, benefits, and alternatives of the medication to patients. In addition, a review of the decision to forcibly medicate patients was conducted by both the treatment team and the medical director.

Rule of Law

Issue

Holding and Reasoning (Weis, J.)

Concurrence (Garth, J.)

Concurrence (Seitz, C.J.)

Dissent (Gibbons, J.)

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