Knecht v. Gillman

Gary Knecht and Ronald Stevenson (plaintiffs) were inmates of an Iowa medical facility that provided mental-health treatment to mentally ill or psychologically disturbed individuals in a secured setting. The facility had a behavior-modification protocol in which inmates were injected with apomorphine as a form of aversive stimuli for inmates with behavioral problems. The drug would cause temporary cardiovascular effects and make the injected inmate vomit for an extended period of time. The drug was administered for any number of behavioral violations, from lying to talking against orders. Injections were given by nurses in a water closet next to the nurses’ station and were often given based on second-hand accounts of inmates’ violations. It was unclear whether initial consent to the injections was obtained; however, when inmates tried to withdraw consent, their withdrawals were refused. The success of aversive stimuli in modifying behavior was questionable, with one expert noting only a 20–50 percent success rate in the treatment, and no other mental-health facility in the state employed it. Knecht and Stevenson, who had both been subjected to apomorphine injections without their consents, sued various state officials (defendants), alleging that the injections constituted cruel and unusual punishment and seeking an injunction against their further use. A United States district court dismissed the pair’s complaint. Knecht and Stevenson appealed.