Law School Case Brief
Vitek v. Jones - 445 U.S. 480, 100 S. Ct. 1254 (1980)
Involuntary commitment to a mental hospital is not within the range of conditions of confinement to which a prison sentence subjects an individual. A criminal conviction and sentence of imprisonment extinguish an individual's right to freedom from confinement for the term of his sentence, but they do not authorize a state to classify him as mentally ill and to subject him to involuntary psychiatric treatment without affording him additional due process protections.
Jones, a convicted felon, was transferred from state prison to a mental hospital pursuant to a Nebraska statute (§ 83-180 (1)) which provided that if a designated physician or psychologist found that a prisoner "suffers from a mental disease or defect" that "cannot be given proper treatment" in prison, the Director of Correctional Services was authorized to transfer the prisoner to a mental hospital. In an action challenging the constitutionality of § 83-180 (1) on procedural due process grounds, a federal district court declared the statute unconstitutional as applied to Jones, holding that transferring him to the mental hospital without adequate notice and opportunity for a hearing deprived him of liberty without due process of law contrary to the Fourteenth Amendment and that such transfers must be accompanied by adequate notice, an adversary hearing before an independent decisionmaker, a written statement by the factfinder of the evidence relied on and the reasons for the decision, and the availability of appointed counsel for indigent prisoners. The court permanently enjoined the State from transferring Jones (who meanwhile had been transferred back to prison) to the mental hospital without following the prescribed procedures. Subsequently, Jones was paroled on condition that he accept mental treatment, but he violated that parole and was returned to prison. Relying on Jones' history of mental illness and the State's representation that he was a serious threat to his own and others' safety, the district court held that the parole and revocation thereof did not render the case moot because Jones was still subject to being transferred to the mental hospital.
Did the parole and revocation of parole render the case moot?
The Supreme Court of the United States held that the case was not moot. The Court found that Jones had a liberty interest not to be transferred to a mental hospital unless he suffered from a mental disease that could not be adequately treated in prison. The stigmatizing consequences of a transfer to a mental hospital for involuntary psychiatric treatment, coupled with the subjection of Jones to mandatory behavior modification as a treatment for mental illness, constituted the kind of deprivations of liberty that required procedural protections. The Court held that Neb. Rev. Stat. § 83-180(1) entitled Jones to due process before he was found to have a mental disease and transferred to a mental hospital. Notice was essential to afford Jones an opportunity to challenge the contemplated action and to understand the nature of what was happening to him. The independent decisionmaker that conducted the transfer hearing was not required to come from outside the prison or hospital administration.
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