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William Dixon v. Caspar Weinberger

405 F. Supp. 974 (1975)

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William Dixon v. Caspar Weinberger

United States District Court for the District of Columbia

405 F. Supp. 974 (1975)

Facts

A class-action suit was filed by William Dixon (plaintiff) against federal and state officials in the District of Columbia, including Caspar Weinberger (defendant). The class covered patients institutionalized at the federally funded St. Elizabeths Hospital (the hospital) under the 1964 Hospitalization of the Mentally Ill Act. The majority of patients at the hospital were District of Columbia residents, and the district and the hospital shared equally in the treatment costs. Dixon sought declaratory judgment that under the act, patients at the hospital were entitled to outpatient placement in other facilities, such as nursing homes, foster homes, or half-way houses. District officials argued that the right to the least restrictive environment only applies to commitment decisions and not treatment options. The district also argued that if the right to alternative placement applied, the hospital was responsible for placements. The hospital’s federal defendants argued that the burden to warrant alternative placement was not met and that even if the burden had been met, the district and not the hospital was responsible for finding adequate placements.

Rule of Law

Issue

Holding and Reasoning (Robinson, J.)

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