O'Connor v. Donaldson
Annotate this Case
422 U.S. 563 (1975)
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U.S. Supreme Court
O'Connor v. Donaldson, 422 U.S. 563 (1975)
O'Connor v. Donaldson
Argued January 15, 1975
Decided June 26, 1975
422 U.S. 563
Respondent, who was confined almost 15 years "for care, maintenance, and treatment" as a mental patient in a Florida state hospital, brought this action for damages under 42 U.S.C. § 1983 against petitioner, the hospital's superintendent, and other staff members, alleging that they had intentionally and maliciously deprived him of his constitutional right to liberty. The evidence showed that respondent, whose frequent requests for release had been rejected by petitioner notwithstanding undertakings by responsible persons to care for him if necessary, was dangerous neither to himself nor others, and, if mentally ill, had not received treatment. Petitioner's principal defense was that he had acted in good faith, since state law, which he believed valid, had authorized indefinite custodial confinement of the "sick," even if they were not treated and their release would not be harmful, and that petitioner was therefore immune from any liability for monetary damages. The jury found for respondent and awarded compensatory and punitive damages against petitioner and a codefendant. The Court of Appeals, on broad Fourteenth Amendment grounds, affirmed the District Court's ensuing judgment entered on the verdict.
1. A State cannot constitutionally confine, without more, a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends, and since the jury found, upon ample evidence, that petitioner did so confine respondent, it properly concluded that petitioner had violated respondent's right to liberty. Pp. 422 U. S. 573-576.
2. Since the Court of Appeals did not consider whether the trial judge erred in refusing to give an instruction requested by petitioner concerning his claimed reliance on state law as authorization for respondent's continued confinement, and since neither court below had the benefit of this Court's decision in Wood v. Strickland, 420 U. S. 308, on the scope of a state official's qualified immunity under 42 U.S.C. § 1983, the case is vacated and
remanded for consideration of petitioner's liability vel non for monetary damages for violating respondent's constitutional right. Pp. 576-577.
493 F.2d 507, vacated and remanded.
STEWART, J., delivered the opinion for a unanimous Court. BURGER, C.J., filed a concurring opinion, post, p. 422 U. S. 578.