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Thomas S., by his guardian ad litem, Joyce M. Brooks v. David T. Flaherty

902 F.2d 250 (1990)

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Thomas S., by his guardian ad litem, Joyce M. Brooks v. David T. Flaherty

United States Court of Appeals for the Fourth Circuit
902 F.2d 250 (1990)

Facts

Thomas S. (plaintiff) obtained class certification from the district court for patients with intellectual disabilities housed in North Carolina public psychiatric hospitals receiving inadequate care. The district court enjoined David Flaherty (defendant), secretary of the Department of Human Resources for North Carolina (the department), after finding that the department had failed to comply with the recommended treatment plans of treating physicians. The court also found that recommendations related to medications, restraints, and living arrangements were not in compliance with professional judgment. Flaherty appealed the district court’s order to the Fourth Circuit Court of Appeals, arguing that the department was in compliance with recommended treatment plans and that the court did not defer to the treating doctors. In addition, Flaherty argued that the institutions’ accreditations established a presumption of adequate care.

Rule of Law

Issue

Holding and Reasoning (Butzner, J.)

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