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Parham v. J. R.

United States Supreme Court
442 U.S. 584 (1979)


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 retarded by the agency. J. L. (plaintiff) was admitted to a Georgia state mental institution in 1972 at age seven 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 admit their children to mental institutions with a signed application and review by the superintendent of the institution. If the superintendent determined that the child showed evidence of mental illness, the superintendent had the power to institutionalize the child indefinitely. On October 24, 1975, J. R. and J. L. filed a declaratory judgment action claiming that Georgia’s voluntary commitment procedures for juveniles violated their due process rights, seeking 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. Due process rights require an independent medical review, and the superintendent review procedure was insufficient, because it was arbitrary and not independent. The state appealed.

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