O'Connor v. Donaldson (1975)

By Stephanie Aguilar

Overview

O’Connor v. Donaldson (1975) is a landmark Supreme Court case where the Court ruled that “a state could not constitutionally confine… a non-dangerous individual who could survive safely in freedom by himself, or with the help of willing and responsible family members or friends.” The decision established that mental illness alone is not a sufficient reason for involuntary commitment without proof that the individual is dangerous to others or unable to live independently. 

Summary

In 1957, Kenneth Donaldson was involuntarily committed to the Florida State Hospital by the petition of his father, who believed Donaldson was suffering from delusions. He remained there for 15 years. Following his release, Donaldson brought a legal action against J. B. O’Connor, the hospital’s superintendent, and several other employees, alleging that they had intentionally violated his constitutional right to liberty. 

During his time at the hospital, Donaldson made numerous requests for release and provided evidence that he posed no threat to others. Moreover, individuals such as John Lembeke, and Helping Hands, Inc., a halfway house, submitted letters for Donaldson’s release, expressing willingness to provide him with care. Despite these efforts, Donaldson’s requests were continuously denied. Ironically, Donaldson did not receive any medical treatment during his confinement; instead, the hospital only provided custodial care. 

In O’Connor v. Donaldson (1975), J. B. O’Connor maintained the defense of acting in good faith and that state law allowed this indefinite custodial confinement. He argued that state law permitted confinement without treatment or release, even if individuals were not deemed dangerous or harmful to others. 

The jury trial in the District Court for the Northern District of Florida ruled in favor of Donaldson. J. B. O’Connor appealed the decision, and the U.S. Court of Appeals for the Fifth Circuit upheld the judgment. The appellate court held that if a patient is confined for treatment, then these individuals have the constitutional right to receive treatment. J. B. O’Connor then petitioned for certiorari, which the United States Supreme Court granted. 

In the unanimous opinion, written by Justice Potter Stewart, the Supreme Court concluded that the State could not constitutionally confine a non-dangerous individual to a mental hospital if that person can survive safely on their own or with the help of family or friends. J. B. O’Connor, the petitioner, was found to have violated Kenneth Donaldson’s constitutional right to liberty because he “confined Donaldson while knowing he was not dangerous” (Shawn M. Wold 606). Furthermore, the Court addressed the need for the U.S. Court of Appeals to reevaluate the instructions given by the trial judge regarding O’Connor’s reliance on state law, leading to the decision of the U.S. Court of Appeals for the Fifth Circuit to be vacated and remanded for further review. 

Impact

O’Connor v. Donaldson (1975) has a massive impact on the rights of individuals with mental disabilities and the reform of mental institutions. Before this case, many individuals diagnosed with mental illnesses, like Kenneth Donaldson, would be confined to institutions indefinitely and would not receive proper treatment. The ruling in this case not only protected the rights of individuals with mental health disabilities but also established standards for involuntary commitment. The landmark decision established that individuals with mental illnesses could only be involuntarily confined if they were a threat to themselves or others, or if they lack the ability to live independently. 

Many individuals were released from mental institutions following the ruling of O’Connor v. Donaldson. According to Shawn M. Wold, only a small number of patients “were actually found to be dangerous at the time of their commitment” (604) leading to a noticeable decrease of patients within institutions. In 1975, The New York Times even estimated that thousands of “untreated” and “harmless” patients would be released following the Supreme Court decision.

O’Connor v. Donaldson was a landmark case that significantly impacted mental health laws and institutions. It brought public attention to the rights of individuals with mental disabilities and gathered support for the protection of these rights. The case led to significant reforms within institutions, improving the treatment of individuals with mental disabilities. 

Court Documents 

To read the full Supreme Court Opinions and Dissents, click here: 

O'Connor v. Donaldson, 422 U.S. 563 (1975), https://supreme.justia.com/cases/federal/us/422/563/ 

To listen to the oral argument of the O’Connor v. Donaldson case, click here: 

"O'Connor v. Donaldson." Oyez, www.oyez.org/cases/1974/74-8. 

Citations

O'Connor v. Donaldson, 422 U.S. 563 (1975), https://supreme.justia.com/cases/federal/us/422/563/. Accessed on 23 May 2024. 

Weaver, Warren Jr. “HIGH COURT CURBS POWER TO CONFINE THE MENTALLY ILL.” The New York Times, 27 June 1975. https://www.nytimes.com/1975/06/27/archives/high-court-curbs-power-to-confine-the-mentally-ill-if-not-dangerous.html. Accessed on 26 May 2024.

Wold, Shawn M. O'Connor v. Donaldson: Due Process and the Involuntarily Civilly Committed Mental Patient, 11 Tulsa L. J. 604 (1976). Available at: https://digitalcommons.law.utulsa.edu/tlr/vol11/iss4/7. Accessed on 26 May 2024.