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.
Rule of Law
Holding and Reasoning (Burger, C.J.)
Concurrence/Dissent (Brennan, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 176,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.