Rennie v. Klein
Encyclopedia
Rennie v. Klein was a case heard in the Federal District Court of New Jersey
in 1978 to decide whether an involuntarily committed
mental patient has a constitutional right to refuse psychiatric medication
. It was the first case to establish that such a patient has the right to refuse medication.
. His case was brought in December 1977. Rennie's psychiatric history indicates that he did not show signs of mental illness
until he was 31. His first hospitalization occurred in 1973 and subsequently he became a revolving door patient, primarily, as trial judge Stanley Brotman noted, because of "his failure to continue taking medications after he has left the hospital's custody." He had been given various diagnoses over time including paranoid schizophrenia and manic-depressive psychosis
. Rennie had persistent religious delusions (he thought he was Christ
) and suicidal ideation
. His eighth hospitalization was initiated after he threatened to kill President Ford
. On subsequent hospitalizations he became increasingly abusive and assaultive.
In December 1977, during his twelfth hospitalization that began on August 10, 1976, doctors had unsuccessfully tried various psychiatric medications. Rennie sued in federal district court to prevent the hospital from administering psychotropic medications to him without a clear emergency. His counsel was the Office of the Public Advocate. As Judge Brotman describes in his decision, the precipitating factors occurred earlier in the month when Rennie had become homicidal. Hospital staff felt his condition was deteriorating, and to prevent Rennie from harming other patients, staff and himself, the treatment team administered prolixin decanoate, an injectable long-acting drug, because of his history of failing to take medication once released. They believed the drug would be the easiest drug on which to maintain him after release. Following initiation of the prolixin regime, Rennie's condition did improve markedly.
Judge Brotman responded to Rennie's appeal for an injunction by issuing a compromise ruling. Rather than enjoining the hospital from giving him any medication, he insisted that the prolixin be lowered to a minimum maintenance dosage, which staff psychiatrists considered too low. He then conducted fourteen days of hearings between January 13 and April 28, 1978.
Several months after issuing his initial ruling that asserted a right to refuse treatment grounded in a constitutional right to privacy, Judge Brotman made the case into a class action that included all involuntarily committed patients at the five mental health facilities operated by the state of New Jersey and held an additional seventeen days of hearings.
rights to freedom of speech or to practice his religion, or his Eighth Amendment
rights to be free of cruel and unusual punishment
. New Jersey's administrative policies, which provide for a second psychiatric opinion in the case of refusing patients, must give adequate scope for the exercise of that right to satisfy constitutional requirements. Additionally, due process
must be followed in order to forcibly medicate an individual against his will. Judge Brotman's order that the least restrictive alternative concept applied to choice of medications was upheld upon appeal.
However, as this case illustrates, applying the least restrictive principles and working with a patient on medication choices brings up difficult empirical issues in ranking treatment options in accord with constitutional rights.
United States District Court for the District of New Jersey
The United States District Court for the District of New Jersey is the federal district court whose jurisdiction is the state of New Jersey....
in 1978 to decide whether an involuntarily committed
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
mental patient has a constitutional right to refuse psychiatric medication
Psychiatric medication
A psychiatric medication is a licensed psychoactive drug taken to exert an effect on the mental state and used to treat mental disorders. Usually prescribed in psychiatric settings, these medications are typically made of synthetic chemical compounds, although some are naturally occurring, or at...
. It was the first case to establish that such a patient has the right to refuse medication.
Circumstances
John Rennie, age 38, was a former pilot and flight instructor who was a patient at Ancora State Hospital in New JerseyNew Jersey
New Jersey is a state in the Northeastern and Middle Atlantic regions of the United States. , its population was 8,791,894. It is bordered on the north and east by the state of New York, on the southeast and south by the Atlantic Ocean, on the west by Pennsylvania and on the southwest by Delaware...
. His case was brought in December 1977. Rennie's psychiatric history indicates that he did not show signs of mental illness
Mental illness
A mental disorder or mental illness is a psychological or behavioral pattern generally associated with subjective distress or disability that occurs in an individual, and which is not a part of normal development or culture. Such a disorder may consist of a combination of affective, behavioural,...
until he was 31. His first hospitalization occurred in 1973 and subsequently he became a revolving door patient, primarily, as trial judge Stanley Brotman noted, because of "his failure to continue taking medications after he has left the hospital's custody." He had been given various diagnoses over time including paranoid schizophrenia and manic-depressive psychosis
Bipolar disorder
Bipolar disorder or bipolar affective disorder, historically known as manic–depressive disorder, is a psychiatric diagnosis that describes a category of mood disorders defined by the presence of one or more episodes of abnormally elevated energy levels, cognition, and mood with or without one or...
. Rennie had persistent religious delusions (he thought he was Christ
Christ
Christ is the English term for the Greek meaning "the anointed one". It is a translation of the Hebrew , usually transliterated into English as Messiah or Mashiach...
) and suicidal ideation
Suicidal ideation
Suicidal ideation is a common medical term for thoughts about suicide, which may be as detailed as a formulated plan, without the suicidal act itself. Although most people who undergo suicidal ideation do not commit suicide, some go on to make suicide attempts...
. His eighth hospitalization was initiated after he threatened to kill President Ford
Gerald Ford
Gerald Rudolph "Jerry" Ford, Jr. was the 38th President of the United States, serving from 1974 to 1977, and the 40th Vice President of the United States serving from 1973 to 1974...
. On subsequent hospitalizations he became increasingly abusive and assaultive.
In December 1977, during his twelfth hospitalization that began on August 10, 1976, doctors had unsuccessfully tried various psychiatric medications. Rennie sued in federal district court to prevent the hospital from administering psychotropic medications to him without a clear emergency. His counsel was the Office of the Public Advocate. As Judge Brotman describes in his decision, the precipitating factors occurred earlier in the month when Rennie had become homicidal. Hospital staff felt his condition was deteriorating, and to prevent Rennie from harming other patients, staff and himself, the treatment team administered prolixin decanoate, an injectable long-acting drug, because of his history of failing to take medication once released. They believed the drug would be the easiest drug on which to maintain him after release. Following initiation of the prolixin regime, Rennie's condition did improve markedly.
Judge Brotman responded to Rennie's appeal for an injunction by issuing a compromise ruling. Rather than enjoining the hospital from giving him any medication, he insisted that the prolixin be lowered to a minimum maintenance dosage, which staff psychiatrists considered too low. He then conducted fourteen days of hearings between January 13 and April 28, 1978.
Several months after issuing his initial ruling that asserted a right to refuse treatment grounded in a constitutional right to privacy, Judge Brotman made the case into a class action that included all involuntarily committed patients at the five mental health facilities operated by the state of New Jersey and held an additional seventeen days of hearings.
Decision
An involuntarily committed patient who has not been found incompetent, barring an emergency, has a qualified right to refuse psychotropic medication, especially when forced treatment violates his First AmendmentFirst Amendment to the United States Constitution
The First Amendment to the United States Constitution is part of the Bill of Rights. The amendment prohibits the making of any law respecting an establishment of religion, impeding the free exercise of religion, abridging the freedom of speech, infringing on the freedom of the press, interfering...
rights to freedom of speech or to practice his religion, or his Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
rights to be free of cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
. New Jersey's administrative policies, which provide for a second psychiatric opinion in the case of refusing patients, must give adequate scope for the exercise of that right to satisfy constitutional requirements. Additionally, due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
must be followed in order to forcibly medicate an individual against his will. Judge Brotman's order that the least restrictive alternative concept applied to choice of medications was upheld upon appeal.
Significance
Before this case, although attention had been focused on involuntary commitment standards, it was assumed that once the patient was hospitalized, hospitals could administer psychoactive medication without consulting either the patient or the family. This was the first case in which the focus shifted from standards of commitment to standards of treatment once hospitalized. This was the first of a series of cases that increasingly acknowledged patient rights to refuse treatment and right to least restrictive treatment by way of a variety of First Amendment rights including freedom of religion and thought as well as the ultimate right to privacy, control over one's own body.However, as this case illustrates, applying the least restrictive principles and working with a patient on medication choices brings up difficult empirical issues in ranking treatment options in accord with constitutional rights.
See also
- O'Connor v. DonaldsonO'Connor v. DonaldsonO'Connor v. Donaldson, 422 U.S. 563 , was a landmark decision in mental health law. The United States Supreme Court ruled that a state cannot constitutionally confine, without more, a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing...
- United States v. BinionUnited States v. BinionUnited States v. Binion, 132 F. App'x 89 , is a case in which the United States Court of Appeals for the Eighth Circuit applied two recent U.S. Supreme Court decisions United States v. Binion, 132 F. App'x 89 (8th Cir. 2005), is a case in which the United States Court of Appeals for the Eighth...
- Washington v. HarperWashington v. HarperWashington v. Harper 494 U.S. 210 is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic medication.-Circumstances:...
- Jackson v. IndianaJackson v. IndianaJackson v. Indiana was a landmark decision of the U.S. Supreme Court that determined a state violated due process by involuntarily committing a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial on the charges filed against...
- Perry v. LouisianaPerry v. LouisianaPerry v. Louisiana is a case brought before the U.S. Supreme Court over the legality of the forcibly medicating a death row inmate with a mental disorder in order to render him competent to be executed.-Circumstances:...
- Rogers v. OkinRogers v. OkinRogers v. Okin was a landmark case in which the United States Court of Appeals for the First Circuit considered whether a mental patient, committed to a state psychiatric facility and assumed to be competent, has the right to make treatment decisions in non-emergency...
- Youngberg v. RomeoYoungberg v. RomeoYoungberg v. Romeo, 457 U.S. 307 , was a landmark United States Supreme Court case regarding the rights of the involuntarily committed and mentally retarded. Nicholas Romeo was mentally retarded with an infant level IQ and was committed to a Pennsylvania state hospital...