Lake v. Cameron

Mrs. Lake (plaintiff) was confined to a state hospital after a police officer found her wandering, unaware of her surroundings. Lake was admitted to the hospital, pending commitment proceedings, and was diagnosed with a senile brain disease associated with aging and accompanied by memory loss. Two hospital psychiatrists noted that at times Lake could not remember the date or where she was. While awaiting her commitment hearing, Lake filed a writ of habeas corpus in a United States district court, naming the hospital’s superintendent, Cameron, as a defendant. Lake’s writ was summarily dismissed, but she appealed. While her habeas appeal was pending, Lake was committed to the hospital by state-court order based on the testimony of the two hospital psychiatrists who concluded that Lake’s condition left her unable to care for herself. Meanwhile, a United States court of appeals remanded the district court’s habeas dismissal for a hearing. At Lake’s habeas hearing, another psychiatrist noted that Lake had wandered away from the hospital for 32 hours and suffered a minor injury after being chased by a group of boys, but overall Lake’s condition had improved during her hospitalization. Lake had also been molested once while wandering in her demented state, but she believed that she could live safely without hospitalization. Lake was supported by her husband and sister, who did not have adequate resources to care for Lake but shared the desire that she not be confined to the state hospital. The district court denied Lake’s release again but stated that she could reapply if she found an adequate care facility. A new law became effective after the district court’s decision, encouraging courts to consider the entire spectrum of available services when ordering involuntary mental-health treatment. Lake then appealed the district court’s habeas dismissal.