Parham v. J. R.

J. R. (plaintiff) was admitted to a Georgia state mental institution at age seven, upon the recommendation of a child-service agency after he was removed from his seventh foster home. J. R. was uncontrollable at school and determined to be borderline intellectually disabled by the agency. J. L. (plaintiff) was admitted to a Georgia state mental institution at age six upon the request of his parents, because he was expelled from school for uncontrollable behavior, and the parents were unable to control him at home. Georgia law permitted parents to voluntarily admit their children to mental institutions with a signed application and review by the institution's superintendent of the recommendations of a physician and institution staff. If the superintendent determined that the child showed evidence of mental illness, the superintendent had the power to institutionalize the child. On October 24, 1975, J. R. and J. L. filed a declaratory-judgment class action against Georgia state officials and hospital personnel (defendants). The plaintiffs claimed that Georgia’s voluntary commitment procedures for juveniles violated their due-process rights, and they sought an injunction against future enforcement of the procedures. The district court held that the commitment procedures were unconstitutional, finding that commitment to a mental institution deprived the child’s liberty and, therefore, invoked due-process rights. The court said that due-process rights require an independent medical review, and the superintendent review procedure was insufficient because it was arbitrary and not independent. The defendants appealed.