On February 28, 1978, persons confined as patients in California under the Welfare and Institutions Act filed this class action in the U.S. District Court for the Northern District of California. The plaintiffs filed under 42 U.S.C. § 1983 against the California Department of Mental Health (CDMH), the California Department of Developmental Services (CDDS), and the California Department of Health Services (CDHS). Represented by the American Civil Liberties Union and private counsel, they sought declaratory and injunctive relief, alleging that they had been administered antipsychotic medication without informed consent in violation of their Fourteenth Amendment right to due process.
After negotiations led to adoption of regulations concerning the rights of voluntary patients to informed consent, on February 27, 1981, the District Court (Judge William H. Orrick) dismissed that portion of the complaint.
On May 12, 1981, the plaintiffs submitted a Second Amended Complaint and the District Court (Judge Orrick) certified a class consisting of adult patients at Napa State Hospital who had been or in the future would be administered antipsychotic medications and who belonged to a list of enumerated subclasses. The subclasses included (a) patients detained for 72 hours of evaluation and treatment or (b) for 14 days of intensive treatments, and (c) committed by a temporary conservatorship or (d) by a conservator.
Further negotiations ensued and in April 1983 the parties submitted a consent decree to the District Court. Under the consent decree, the parties agreed that administration of antipsychotic drugs without informed consent to patients in any of the four subclasses implicated a liberty interest protected by the Due Process clause. In effect, the consent decree permanently enjoined the CDMH from administering antipsychotic medications to persons in the subclasses and established procedures and standards for administration of such drugs and a selection of independent reviewers. Further, under the consent decree the court retained control of the matter to monitor the defendants' compliance as well as to modify the terms of the agreement. Judge William H. Orrick approved the consent decree on December 13, 1983.
On March 26, 1984, the court ordered the defendants to pay $600,000 in attorneys' fees and costs to the plaintiffs.
The defendants filed one status report on November 30, 1984. The consent decree remained extant, but there were no additional docket entries until 2010.
On December 17, 2010, the court received a letter from personnel at Napa State Hospital responsible for assisting the hospital to maintain compliance with the terms of the consent decree. The letter explained that the hospital had been unable to fulfill the requirements of the consent decree since October 2010 and inquired whether there had been a modification or abandonment of the terms of the consent decree. District Judge William Alsup, who had been assigned the case while it was dormant, realized he had been an attorney for the plaintiffs in this case and recused himself from the case on January 3, 2011. The case was reassigned to Judge Saundra Brown Armstrong.
As of March 9, 2019 no new activity has occurred but the case is technically still open.
Josh Altman - 06/15/2006
Nick Kabat - 10/14/2014
Jessica Kincaid - 02/13/2016
Carter Powers Beggs - 10/30/2019
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