Wyatt v. Stickney (1971)
- Sam Shepherd
- Sep 19, 2024
- 5 min read
Updated: Oct 27, 2024
By Andrew Dawson
Overview
In Wyatt v. Stickney, the federal United States District Court for the Middle District of Alabama ruled that individuals who are involuntarily committed to institutions due to mental health or developmental disabilities have a constitutional right to adequate treatment. Further, the Court created a minimum standard of care (known as the Wyatt Standards), which was designed to provide individuals a pathway to cure or improve their condition, and thus, the opportunity to reintegrate into society.
This ruling and the widespread implementation of the Wyatt Standards led to significant reforms in the nation’s mental health systems for patients with mental illnesses and developmental disabilities grounded in the protections afforded by the Fourteenth Amendment of the U.S. Constitution.
Summary
In 1970, the state of Alabama cut its cigarette tax, which aided funding of the state’s mental health services. As a result, this significantly reduced the budget, and had numerous repercussions including widespread layoffs from the state’s mental health system. Consequently, a number of laid off staff from Bryce Hospital filed a lawsuit, alleging insufficient staff would lead to inadequate treatment, which would violate their civil rights under the Fourteenth Amendment (Encyclopedia of Alabama). Also included within the suit was fifteen-year-old patient Ricky Wyatt, whose legal guardian was among the laid off staff. Wyatt had been placed in Bryce Hospital by a court order classifying him as a “juvenile delinquent,” in order to “attempt to control his behavior,” yet was without any diagnosis of a mental illness or disability (Disability Justice).
This case became a class-action lawsuit with the addition of patients from Searcy Hospital for mental health and Partlow State School and Hospital for individuals with developmental disabilities to the plaintiffs. Federal District Judge Frank M. Johnson dismissed the case brought by the professionals, citing the Alabama Department of Mental Health (the defendants) had the right to lay off employees. However, Judge Johnson allowed the case on behalf of the patients (Encyclopedia of Alabama).
On March 12, 1971, Judge Johnson ordered a preliminary injunction for the plaintiffs stating that patients involuntarily committed “unquestionably have a constitutional right to receive such individual treatment as will give each of them a realistic opportunity to be cured or to improve his or her mental condition.” Further, Judge Johnson stated, “To deprive any citizens of his or her liberty upon the altruistic theory that the confinement is for humane therapeutic reasons and then fail to provide adequate treatment violates the very fundamentals of due process” (Disability Justice).
This ruling gave the Alabama Department of Mental Health six months to establish and implement appropriate treatment standards and programs at the three hospitals. However, due to lack of resources, this never came to fruition. During this time, numerous organizations including the Department of Justice’s Civil Rights Division, the American Psychological Association, and American Civil Liberties Union were allowed to participate in the case as amicus curiae (impartial advisors) (Encyclopedia of Alabama).
On December 10, 1971, after the Alabama Department of Mental Health failed to establish and implement treatment standards in the alloted time, Judge Johnson intervened and ordered “three fundamental conditions for adequate and effective treatment programs in public mental institutions,” These became known as the “Wyatt Standards”:
A humane psychological and least physical environment;
Qualified staff in numbers sufficient to administer adequate treatment; and
Individualized treatment plans (Disability Justice).
Following the establishment of these three principles, the court heard a variety of testimony including from organizations who joined the case as amicus curiae, experts on mental health and developmental disabilities, and staffers. From this testimony, the court heard of the conditions within the three institutions in Alabama, and recommendations on what reforms to implement to improve treatment. The conditions within Alabama hospitals were indisputably appalling, ranking 50/50 for expenditures, staffing and treatment were deplorably inadequate, including one clinical psychologist, three medical doctors, and two social workers for 5,200 patients (Disability Justice).
On April 13, 1972, Judge Johnson concluded the three hospitals were all deficient of these principles and issued two issued two historic rulings, one covering Bryce and Searcy Hospitals regarding patients committed for mental health, and the second for Partlow and developmental disabilities. In the two rulings, Judge Johnson sided with the plaintiffs and ordered these three standards of care to be applied to these three public institutions for individuals with mental illness or developmental disabilities (Encyclopedia of Alabama).
In May, 1972, Gov. George Wallace Jr. and the Alabama Mental Health Board appealed Judge Johnson’s ruling to the U.S. Circuit Court of Appeals for the Fifth Circuit. Yet, the Court of Appeals ruled in favor of Judge Johnson’s decision, which affirmed the Wyatt Standards as national guidelines for medical and legal professions.
Impact
In the following three decades, Wyatt v. Stickney continuously appeared in federal court, including Wyatt v. Aderholt, Wyatt v. Wallis, Wyatt v. King, Wyatt v. Poundstone, and Wyatt by and through Rawlins v. Rogers. These cases primarily challenged the implementation of the Wyatt Standards (Disability Justice). From these cases, rather than face the high costs from the court-imposed Wyatt Standards, many states released a significant portion of patients held within these institutions (Mental Illness Policy).
This was also true in Alabama, where the Department of Mental Health was unable to comply with the Wyatt Standards due to funding and staffing challenges. In June 1977, forced Judge Johnson to place the department under court order to monitor compliance within the standards and report any discrepancies (Encyclopedia of Alabama).
In January 1980, the District Court placed the new Department of Mental Health under the office of Governor, which had improved compliance to the Wyatt Standards, yet still did not fully meet this threshold. In 1986, the Department agreed with the plaintiffs to a new decree (legal order), which required “all facilities to achieve accreditation from the Joint Commission on the Accreditation of Healthcare Organizations and comply with the healthcare facility requirements of Title XIX, the Social Security Act.” This decree added development of quality care, an internal advocacy system, and placement of patients in community centers to the Wyatt Standards. Further, it replaced court ordered monitors and created a pathway for the Department of Mental Health to achieve compliance. By 1999, the state made significant progress towards implementing the goals of the 1986 decree, enabling the court to dissolve this order. Finally, in 2003, Judge Myron Thompson dismissed the case, citing that the state had satisfied “ensuring the constitutional right of civilly committed mental patients to receive adequate treatment”(Encyclopedia of Alabama).
Court Documents
Citations
“Case: Wyatt v. Stickney.” Wyatt v. Stickney: 2:70-Cv-03195 | U.S. District Court for the Middle District of Alabama, clearinghouse.net/case/404/. Accessed 17 Sept. 2024.
“Right to Treatment: Wyatt v. Stickney - Case Summary.” Mental Illness Policy Org, 23 Jan. 2019, mentalillnesspolicy.org/legal/wyatt-stickney-right-treatment.html.
“Wyatt v. Stickney.” Disability Justice, 1 June 2023, disabilityjustice.org/wyatt-v-stickney/.
“Wyatt v. Stickney.” Encyclopedia of Alabama, 11 Oct. 2023, encyclopediaofalabama.org/article/wyatt-v-stickney/.
