Wyatt v. Stickney

Wyatt filed suit in the United States District Court for the Middle District of Alabama, representing a class of mentally ill individuals (plaintiffs) who were involuntarily confined in Alabama mental-health facilities for treatment purposes. In a formal opinion, the district court held that Alabama had denied the class members their constitutional right to adequate treatment and ordered the facilities to raise their levels of care to minimum constitutional standards within six months. The court ordered the facilities to file a final report detailing their implementations of medically and constitutionally sufficient treatment programs at the conclusion of the six months. At that time, the court concluded that the facilities were constitutionally deficient for their failures to provide (1) humane psychological and physical environments; (2) qualified staff in sufficient numbers to ensure administration of adequate treatment; and (3) individualized treatment plans to ensure that each patient had a reasonable opportunity to be cured or have his or her condition improved. The court’s conclusion was based on evidence that the facilities were understaffed and overcrowded, rendering treatment virtually impossible. Patients were assigned nontherapeutic and uncompensated work and had no semblance of privacy. The staff was poorly trained, and there were several emergency and fire hazards noted throughout each of the facilities. The court ordered that each of the parties, along with amici, file proposed standards for constitutionally adequate treatment.