Spencer v. Lee

In 1984, William Spencer (plaintiff) was involuntarily committed to a private hospital upon the authorization of Dr. Bumyong Lee (defendant) due to Spencer’s history of schizophrenia and suicidal tendencies. Dr. Lee authorized Spencer’s commitment pursuant to Illinois’s mental-health code, which allowed Lee to commit Spencer for up to five days, excluding weekends, based on the doctor’s opinion that Spencer posed danger of physical harm to himself or others. The code required that Dr. Lee file a petition with the hospital and a state court containing the factual basis for the confinement and a certification that Lee had seen Spencer within the previous 72 hours and determined that immediate hospitalization was required. The hospital was then authorized to hold Spencer until a judge determined whether further confinement was warranted. Spencer was unwillingly taken to the hospital by police and was hospitalized for five days. On the fourth day, Spencer received an injection of medication directed by Dr. Lee. Spencer had a reaction to the medication causing bodily injury and sued Dr. Lee as a pro se plaintiff in a United States district court. The district judge dismissed Spencer’s complaint for failure to state a claim. Spencer appealed seeking damages under 42 U.S.C. § 1983, alleging that Illinois’s mental-health code deputized Dr. Lee as a state actor to confine him without due process.