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Zinermon v. Burch

United States Supreme Court
494 U.S. 113 (1990)


Facts

On December 7, 1981, Darrell Burch (plaintiff) was admitted to a private mental health facility in Florida after being found wandering along a highway in a disoriented state. He remained at the facility for three days, where he was diagnosed as paranoid schizophrenic and given psychotropic medication, before being taken to the Florida State Hospital (FSH). At FSH, Burch signed several forms requesting voluntary admission and consenting to treatment. Staff notes indicated that Burch was extremely psychotic, paranoid, and hallucinating upon admission. FSH admission policies dictate that voluntary patient admissions could be made only upon informed consent, while more extensive admission procedures were prescribed for those persons incapable of giving informed consent. No hearing was held regarding Burch’s hospitalization or treatment during his five months at FSH. Burch brought a § 1983 action in the United States District Court for the Northern District of Florida against staff physician Dr. Zinermon and 10 other FSH staff members (defendants), alleging deprivation of liberty without due process for admitting him as a voluntary patient while he was incompetent. The district court granted a defense motion to dismiss, the court of appeals reversed and remanded, and the United States Supreme Court granted certiorari.

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Holding and Reasoning (Blackmun, J.)

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Dissent (O’Connor, J.)

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