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Law School Case Brief

Washington v. Harper - 494 U.S. 210, 110 S. Ct. 1028 (1990)

Rule:

The proper standard for determining the validity of a prison regulation claimed to infringe on an inmate's constitutional rights is to ask whether the regulation is "reasonably related to legitimate penological interests." This is true even when the constitutional right claimed to have been infringed is fundamental, and the State under other circumstances should have been required to satisfy a more rigorous standard of review.

Facts:

Petitioners petitioned for certiorari to the Supreme Court of Washington, which held that a Washington state policy that allowed prison authorities to administer medication to inmates against their will was unconstitutional because it deprived the inmates of their due process rights.

Issue:

Does Wasington state's policy allowing prison authorities to administer medication to inmates against their will deprive them of their due process rights?

Answer:

No.

Conclusion:

The United States Supreme Court recognized that inmates had a Fourteenth Amendment right to refuse treatment. The court reasoned that the right to be free of medication had to be balanced against the state's duty to treat mentally ill inmates and run a safe prison. However, the court concluded the State's procedures did not deprive inmates of the right to refuse treatment without adequate due process. In this case, the policy states that inmates who refused to take the medication voluntarily could request a hearing before a special committee to review the decision. Inmates had a right to attend the hearing, present evidence, and cross-examine the staff. Finally, continuous treatment could only occur with periodic review by a physician, and inmates could have a new hearing every 180 days.

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