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Thomas S., Joyce M. Brooks, Appointed Guardian Ad Litem v. Sarah T. Morrow

United States Court of Appeals for the Fourth Circuit

781 F.2d 367 (1986)

Facts

Sarah Morrow (defendant), secretary of the Department of Human Resources for North Carolina (the department), appealed the district court’s finding that the department had violated Thomas S.’s (plaintiff) liberty interests by placing him in a detox facility, rather than a group home; not complying with the recommended treatment plan; and not protecting him from a suicide attempt. Morrow argued that Youngberg v. Romeo was inapplicable because Thomas was not institutionalized and was receiving minimally adequate treatment that complied with professional standards. Morrow also argued that local government was responsible for Thomas’s care and not the state. Finally, Morrow argued that summary judgment was inappropriate due to genuine issues of material fact in the record.

Rule of Law

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Issue

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Holding and Reasoning (Butzner, 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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