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Rubie Rogers v. Commissioner of the Department of Mental Health

Massachusetts Supreme Court

458 N.E.2d 308 (1983)

Facts

The First Circuit Court of Appeals certified nine questions to the Massachusetts Supreme Court related to the rights of involuntarily committed patients to refuse antipsychotic drugs. The court found the following: (1) involuntary commitment is not a finding of incompetence; (2) incompetence requires a legal finding made by a judge; (3) competency issues may be raised in probate, superior, or juvenile courts; (4) before forcibly medicating incompetent patients, the court must employ the substituted-judgment standard and consider the factors from Guardianship of Roe; (5) the treatment plan may only be approved by a judge after notice and hearing, and the guardian must monitor the treatment; (6) no state interest is compelling enough to allow forced antipsychotic medication outside of an emergency; (7) the state’s police power only allows forced medication in emergencies; (8) an emergency includes prevention of “immediate, substantial, and irreversible deterioration of a serious mental illness”; and (9) if doctors plan to continue with the course of treatment under that standard, the patient must first be found incompetent.

Rule of Law

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Issue

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Holding and Reasoning (Abrams, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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