Terri Lee Halderman v. Pennhurst State School & Hospital

In 1974, Terri Lee Halderman (plaintiff), a minor with intellectual disabilities, filed a class-action suit against Pennhurst State School and Hospital (the hospital) (defendant), a facility providing care and training for 1,200 individuals with intellectual disabilities. Halderman argued that the hospital violated federal and state statutes that protect individuals with intellectual disabilities because residents were forced to live in dangerous and unsanitary conditions; were physically restrained, isolated, and unnecessarily medicated; lacked access to therapy or services; and were not properly supervised. Halderman argued that the conditions at the hospital resulted in violations of equal protection, due process, and constituted cruel and unusual punishment. In 1977, the district court found that individuals with intellectual disabilities had the constitutionally protected right to nondiscriminatory habilitation (education, training, and care), freedom from harm, and access to the least restrictive environment. The court also found that alternatives to the hospital existed, as federally funded community living arrangements were available. When the parties could not agree on relief, the court issued an injunction ordering that the hospital be closed because institutions are too isolated to provide adequate care, alternative community living arrangements be found for each resident, each resident participate in the development of an individualized treatment plan, a special master supervise the implementation of the plans, no further placements be made at the hospital, a program be developed to represent the class and monitor the arrangements, further abuses at the hospital be prevented, and alternative employment for all hospital employees be found. The hospital appealed to the Third Circuit Court of Appeals.