Filed Date: 1980
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This case involved a dispute between the Commonwealth of Pennsylvania (State) and County of Allegheny (County) over whether the County or the State was responsible under Pennsylvania state law, the Mental Health and Mental Retardation Act of 1966, 50 P.S. s 4101-4704 (1969), for providing long-term care for individuals with intellectual disabilities. The action arose when the County petitioned the Court of Common Pleas for the involuntary commitment of Joseph Schmidt, an individual with an intellectual disability, to an appropriate facility. The State intervened as a party-respondent and asserted that the State-operated facility, known as Western Center, would not be an appropriate facility for Ms. Schmidt and that it was the County's legal responsibility to provide for his care. The Court of Common Pleas found that Mr. Schmidt was an individual with an intellectual disability requiring a closely supervised structured residential program and ordered the County to develop a plan to manage his care within six months. During that six month period, the Court allowed for Mr. Schmidt to be temporarily placed in the Western Center. The County appealed.
On appeal, the Supreme Court of Pennsylvania (Justice Nix) reversed and remanded. In Re: Schmidt, 429 A.2d 631 (Pa. 1981). The Supreme Court interpreted the Mental Health and Mental Retardation Act of 1966, 50 P.S.§ 4101-4704 (1969), to require the State to provide mental retardation services for persons in need of them. The Court reasoned that the State could not ignore its responsibility even if an appropriate facility was not immediately available.
We have no further information on the case.
Summary Authors
Dan Dalton (3/16/2007)
Coval, Thomas E. (Pennsylvania)
Finnerty, Timothy E. (Pennsylvania)
Biondo, Dennis R. (Pennsylvania)
Esler, James A. (Pennsylvania)
Jackson, Marlene W. (Pennsylvania)
Nix, Robert N.C. Jr. (Pennsylvania)
Last updated Aug. 30, 2023, 2:47 p.m.
Docket sheet not available via the Clearinghouse.State / Territory: Pennsylvania
Case Type(s):
Intellectual Disability (Facility)
Key Dates
Filing Date: 1980
Case Ongoing: Unknown
Plaintiffs
Plaintiff Description:
A mentally disabled individual requiring a closely supervised residential program petitioning for the development of a practical life management plan setting forth in detail the type of residential placement appropriate for his needs
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Commonwealth of Pennsylvania, State
Case Details
Causes of Action:
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Order Duration: 1981 - None
Issues
General:
Type of Facility: