LANDMARK CASES R Flashcards
Rennie v. Klein (3rd C. COA 1983) FOTC
Rennie 38M intelligent (pilot) but schizophrenia/BPAD early 30s, numerous hospitalizations/med refusals (threatened to kill Ford). 12th hosp Ancora State (NJ), got invol Prolixin when homicidal.
NJ DMH has Admin Bulletin 78-3 which provided refusing pt entitled to review by tx team then medical director
Rennie sued, claiming forced meds violated 1st A (mental processes) and 8th A
Rennie v. Klein (3rd C. COA 1983) Court Process & Findings (3.1)
- 3rd C. upheld const RTRT and least restrictive applied to meds, but also that state’s policy 78-3 was constitutionally sufficient & hearing not required.
- SCOTUS granted cert, but remanded to 3rd C. to reconsider in light of Youngberg v. Romeo’s “accepted professional judgment” consideration.
- 3rd C. reaffirmed RTRT and that policy was adequate, but said least restrictive was not mandated, rather “accepted professional judgment.”
Standard to measure RTRT was dangerousness to self or others.
Rennie v. Klein (3rd C. COA 1983) Key Point
Invol legally competent pts who refuses meds has right to professional medical review of treating psychiatrist’s decision of best for pt. This decision-making process left to medical prof’s judgment
Contrast b/w Rennie v. Klein (3rd C. COA 1983) vs. Rogers v. Okin (MA Dist. Co. 1979)
Decision-making left to medical professional’s judgment vs. judicial review
Riggins v. Nevada (SCOTUS 1992) FOTC
- Riggins charged w/ murder/robbery
- Dx schiz, successfully tx with Mellaril, then found CST
- Motion to suspend Mellaril until end of trial, saying it would infringe D.P. bc he had right to show jurors his true NGRI state at time of offense
- Motion denied
- Argued NGRI, convicted and sentenced death
- NV SC affirmed, saying expert testimony was sufficient to inform jurors of Mellaril’s effect on his demeanor/testimony
- Appealed SCOTUS
Riggins v. Nevada (SCOTUS 1992) H & R (Scope of Issue, What Required for Fulfill Const, Other Issue Not Investigated, and 2 Issues Not Addressed)
H: Forced admin of antipsychotics violated 6th/14th A rights
R:
- Narrow limiting of issue: only that denied him “full and fair” trial. Said there’s interest in avoiding these meds, so violated D.P.
- Would’ve satisfied if shown medically appropriate & essential for safety (& no less restrictive). However, investigated nothing about these matters/alternatives.
- No investigation if meds impaired his ability to participate w/ defense
- DIDN’T address 1) right to show jury unmedicated state (not presented to lower courts, brought up later), and 2) forced admin to restore competency (bc wasn’t before them)
Riggins v. Nevada (SCOTUS 1992) Dissent
Even if state forced meds, and even if deprived of a protected interest, he had still received a fundamentally fair criminal trial req’d by the constitution when all was said and done
Robinson v. California (SCOTUS 1962) FOTC & Issue
- Robinson convicted being an addict w/in jurisdiction (md to use, be under influence, or be addicted”
- Stopped by LEO and found to have needle marks, admitted to occasional use. No irregular/illegal conduct when stopped
- Appealed SCOTUS
ISSUE: Permissible scope of criminal sanctions for status crimes under 14th A?
Robinson v. California (SCOTUS 1962) H & R
H: Violated 8th A as incorporated into 14th A D.P. to apply to states
R:
- Made “status” of addiction offense, so could be G of offense w/o ever using/possessing in CA
- Same as making it crime to be MI or have other health problems. Might mandate compulsory tx, but can’t punish illness w/ compulsory jail sentence
- Equated status w/ illness
Rock v. Arkansas (SCOTUS 1987) FOTC
- Mrs. Rock charged w/ manslaughter of husband during fight
- Rock told LEO that had choked her, thrown against the wall, hit her, so she shot him
- Couldn’t remember precise details, so atty suggested hypnosis (recorded sessions)
- No new info during sessions, but afterwards, remembered that gun misfired with finger not on trigger. Somewhat corroborated by firearms expert
- Prosecutor objected to hypnotically refreshed testimony
- Judge said must limit testimony to “matters remembered and stated to the examiner prior to being placed under hypnosis”
- Convicted & sentenced to 10 years
- Appealed SCOTUS
Rock v. Arkansas (SCOTUS 1987) H (& 3 Amendments)
Per se exclusion of all hypnotically refreshed testimony infringed on rights to testify on own behalf, infringing 5th, 6th, and 14th As
Rock v. Arkansas (SCOTUS 1987) R (General About Testimony, Safeguards, Big Infringement, and Generalizability)
- Right to testimony not unlimited, but can’t be arbitrary/disproportionate
- Additional safeguards for judicial process (e.g., can still cross-examine hypnotic testimony & other verifications)
- This rule didn’t allow to even consider this testimony, effectively prevented her from describing events at all.
- Possible unreliability, but doesn’t mean that should disregard every case
Rock v. Arkansas (SCOTUS 1987) Dissent
Agreed that majority opinion might be sensible, but shouldn’t be framed under constitution to be imposed on individual states/requiring individual judges to reconsider all these issues
Rogers v. Commissioner (MA SC 1983) FOTC
- Section 1983 class action lawsuit on behalf of Rubie Rogers (& other pts) by Mental Patients Liberation Front at Boston State Hospital against invol meds
Rogers v. Commissioner (MA SC 1983) Initial Distr Co Finding (3)
- Invol meds are Invasion of privacy and 1st A violation.
- Invol pts have right to make tx decisions until adjudicated incompetent by judge.
- Only emergency invol meds could be administered
