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Case Name Knecht v. Gillman MH-IA-0001
Docket / Court 73-1374 ( S.D. Iowa )
State/Territory Iowa
Case Type(s) Mental Health (Facility)
Case Summary
Sometime in 1973, two mental institution inmates at Iowa Security Medical Facility (ISMF) filed a lawsuit under 42 U.S.C. § 1983 against state officials in the U.S. District Court for the Southern District of Iowa, Central Division. The plaintiffs, represented by the Hawkeye Legal Aid Society, ... read more >
Sometime in 1973, two mental institution inmates at Iowa Security Medical Facility (ISMF) filed a lawsuit under 42 U.S.C. § 1983 against state officials in the U.S. District Court for the Southern District of Iowa, Central Division. The plaintiffs, represented by the Hawkeye Legal Aid Society, asked the court for injunctive relief, alleging that the defendants' actions constituted cruel and unusual punishment in violation of the Eighth Amendment. Specifically, the plaintiff contended that they had been, without their consent, subjected to injections of a drug that induced vomiting.

Sometime in 1973, the Magistrate Judge (Judge Unknown) recommended that the complaint be dismissed but that certain precautionary steps needed to be taken in administering the drug if it was to be continued in use at the facility.

Sometime in 1973, the District Court (Judge William C. Stuart) dismissed the complaint and did not adopt the Magistrate Judge's recommendations concerning the drug's future administration. The plaintiffs appealed.

On December 5, 1973, the Eighth Circuit Court of Appeals (Judge Donald Roe Ross) reversed with directions. Knecht v. Gillman, 488 F.2d 1136 (8th Cir. 1973). The Court held that administration of the drug to nonconsenting mental institution inmates constituted cruel and unusual punishment. The Court reasoned that, as ISMF housed both civil and criminal patients, civil patients' compromise of procedural rights in their transfer to ISMF was only justified if the purpose of commitment there was treatment and not punishment. Accordingly, the Court held that the forcing someone to vomit for a fifteen minute period for committing some minor breach of the rules could only be regarded as Pavolovian conditioning qua cruel and unusual punishment unless the treatment was being administered to a patient who knowingly and intelligently consented to it. The Court instructed the District Court to enjoin the defendants from further use of the drug except pursuant to specific guidelines the Court set forth.

Because we have only the Eight Circuit Court of Appeals opinion, we have no more information on this file.

Josh Altman - 06/15/2006


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Issues and Causes of Action
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Issues
Medical/Mental Health
Medication, administration of
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. 1983
Defendant(s) Iowa Security Medical Facility
Iowa State Officials
Plaintiff Description Mental institution inmates brought action to enjoin injections of drugs
Indexed Lawyer Organizations None on record
Class action status sought
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement
Order Duration 1973 - n/a
Case Closing Year n/a
Case Ongoing Unknown
Docket(s)
No docket sheet currently in the collection
General Documents
Reported Opinion 12/05/1973 (488 F.2d 1136)
MH-IA-0001-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Heaney, Gerald William (Eighth Circuit)
MH-IA-0001-0001
Ross, Donald Roe (Eighth Circuit)
MH-IA-0001-0001
Stephenson, Roy Laverne (S.D. Iowa, Eighth Circuit)
MH-IA-0001-0001
Monitors/Masters None on record
Plaintiff's Lawyers Robinson, L. Vern (Iowa)
MH-IA-0001-0001
Defendant's Lawyers Hronek, Thomas R. (Iowa)
MH-IA-0001-0001
Other Lawyers None on record

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