O'Connor v. Donaldson

Kenneth Donaldson (defendant) suffered from paranoid schizophrenia and was civilly committed to confinement in a Florida state hospital for nearly 15 years, pursuant to a since-repealed Florida statute. Following a hearing, Donaldson was committed to the state hospital under the care, custody, and control of Dr. J.B. O’Connor (plaintiff), the hospital’s superintendent for most of Donaldson’s confinement. 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 petitioned for release on several occasions with support from some of the hospital’s staff who conceded that Donaldson had not posed a danger to himself or others while hospitalized and was receiving little treatment, at times simply being confined in a room with dozens of patients with various mental illnesses and reasons for confinement. A halfway house and one of Donaldson’s college friends were willing to assume responsibility for Donaldson and petitioned for Donaldson’s release into their custodial care. Dr. O’Connor never authorized Donaldson’s release based on the belief that Donaldson would not survive without being institutionalized. However, the doctor provided no reasoning for his belief. Donaldson was released a month after Dr. O’Connor retired and sued Dr. O’Connor and several hospital staff members in a United States district court for violating his constitutional right to liberty. Following a trial, a jury agreed with Donaldson and awarded him damages. A United States court of appeals affirmed the judgment, noting that the Constitution requires states to provide minimally adequate treatment to justify confinement of harmless mentally ill individuals. Dr. O’Connor petitioned for certiorari.