Law School Case Brief
Youngberg v. Romeo - 457 U.S. 307, 102 S. Ct. 2452, 73 L. Ed. 2d 28, 1982 U.S. LEXIS 128
As a general matter, a State is under no constitutional duty to provide substantive services for those within its border. When a person is institutionalized and wholly dependent on the State, a duty to provide certain services and care does exist, although even then a State necessarily has considerable discretion in determining the nature and scope of its responsibilities. Nor must a State choose between attacking every aspect of a problem or not attacking the problem at all.
Plaintiff Romeo, a minor, was involuntarily committed to the Pennhurst State School and Hospital, a state institution for the mentally retarded. After he had been injured on numerous occasions while a patient at the institution, Romeo, by and through his mother as next friend, brought an action against defendants, a Pennsylvania state institution and its officials, for violation of his constitutional rights under the Civil Rights Act of 1871. The district court entered judgment for defendants institution and the State officials, but the Court of Appeals for the Third Circuit reversed and remanded. Defendants petitioned for certiorari review.
Was a patient's Fourth Amendment right violated when he was committed to a state institution for the mentally retarded?
The Court vacated the judgment and remanded, holding that the institutionalized patient had substantive rights under the Due Process Clause of the Fourteenth Amendment to safe conditions of confinement, freedom from bodily restraints, and training or "habilitation." The State was under a duty to provide the involuntarally committed patient with such training as an appropriate professional would consider reasonable to ensure his safety.
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