Youngberg v. Romeo (1982)
- Sam Shepherd
- Jun 17, 2024
- 3 min read
Updated: Oct 27, 2024
By Stephanie Aguilar
Overview
Youngberg v. Romeo was a landmark U.S. Supreme Court case where the Court recognized the constitutional rights of individuals with disabilities who are involuntarily committed, establishing their right to “reasonably safe conditions of confinement, freedom from unreasonable bodily restraints,” and “minimally adequate training” (Youngberg v. Romeo).
Summary
Nicholas Romeo, a man with mental disabilities, was involuntarily committed to Pennhurst State School and Hospital. His mother, Mary Romeo, filed a lawsuit on behalf of Nicholas after seeing him sustain numerous injuries while being in the institution’s care. In court, Romeo argued that the institution violated his “constitutional rights to safe conditions of confinement, freedom from bodily restraint, and training or “habilitation” and that [the] petitioners knew, or should have known, about his (Nicholas Romeo) injuries, but failed to take appropriate preventive procedures” (Youngberg v. Romeo).
The respondent presented evidence of Romeo’s injuries, while the petitioner showed evidence of Romeo participating in programs aimed at teaching self-care skills. The Supreme Court Opinion noted that a program designed to reduce Romeo’s aggressive behavior had been proposed but was not implemented due to objections from Romeo’s mother. The jury’s verdict favored the defendant (Youngberg), as they did not find sufficient evidence that Romeo’s constitutional rights had been violated.
However, the Court of Appeals for the Third Circuit “reversed and remanded for a new trial,” ruling that the Eighth Amendment did not apply to “determining the rights of those individuals who are involuntarily committed,” such as Romeo (Youngberg v. Romeo). Instead, the Court concluded that the Fourteenth Amendment “provided the proper constitutional basis for [protecting] these rights” (Youngberg v. Romeo). Under the Fourteenth Amendment, they determined that individuals involuntarily committed have fundamental liberties regarding the freedom of movement and personal security, which can only be restricted “by an ‘overriding, nonpunitive’ state interest” (Youngberg v. Romeo).
The Court of Appeals failed to reach a consensus on the standard to judge whether Romeo’s rights had been violated. However, the majority of the Court did agree on several factors. They conclude that physical restraint could only be justified by “compelling necessity.” Additionally, they determined that failing to ensure a resident’s safety requires demonstrating “substantial necessity.” Finally, it was ruled that if treatment is administered then “those responsible are liable only if the treatment is not ‘acceptable in the light of present medical or other scientific knowledge’” (Youngberg v. Romeo). Overall, the Court created specific standards for physical restraints, and safety measures, and outlined conditions where those responsible for treatment would be held liable.
The Supreme Court ruled that Romeo possesses constitutional rights under the Due Process Clause of the Fourteenth Amendment. This Amendment provides the right to “reasonably safe conditions of confinement, freedom from unreasonable bodily restraints, and such minimally adequate training” (Youngberg v. Romeo). In the Opinion, the Court emphasized the need to balance Romeo’s liberty interests with the state’s justifications for implementing certain conditions or restraints. The Supreme Court introduced a standard for evaluating the protection of these rights, stipulating that a professional must make a judgment. The Court will presume the professional’s judgment is correct and valid until proven otherwise.
Impact
Youngberg v. Romeo established the rights of disabled individuals in institutions under the Fourteenth Amendment, ensuring their right to safe conditions, freedom from restraints, and adequate training.
The ruling in this case has been cited numerous times, influencing legal standards and refining many policies and laws related to the care of individuals with disabilities. Through this legal precedent, Youngberg v. Romeo provides greater protections for involuntarily committed individuals and reinforces the importance of professional oversight in treatment through the professional judgment standard.
This case led to several improvements in the treatment of individuals within institutions due to the increased scrutiny from the State. This oversight led to an elevated standard of care and protections for institutionalized individuals. As a result, initiatives were made to develop better programs and improve treatment practices. Additionally, efforts were made to minimize the use of restraints whenever possible, thus ensuring the rights of individuals with disabilities and promoting their well-being within institutions.
In conclusion, Youngberg v. Romeo was a landmark case that established many protections for institutionalized individuals with disabilities. This decision improved the standard of care and treatment within institutions and influenced laws and policies regarding mentally disabled individuals. The case brought greater awareness and accountability for the care of disabled individuals within institutions.
Court Documents
To read the full Supreme Court Opinions and Dissents, click here:
Youngberg v. Romeo, 457 U.S. 307 (1982), https://supreme.justia.com/cases/federal/us/457/307/
To listen to the oral argument of the Youngberg v. Romeo case, click here:
Citations
Youngberg v. Romeo, 457 U.S. 307 (1982), https://supreme.justia.com/cases/federal/us/457/307/. Accessed on 2 June 2024.
