Wyatt v. Stickney:   Testing the 8 thAmendment & the Right    to Treatment   Sherwood Best, Ph.D.     Professor, CSULA    ...
Wyatt               v.           Stickney       325 F. Supp 781(Middle District of Alabama 1971)       344 F. Supp 373(Mid...
TerminologyHabilitation– Treatment provision forindividuals whose disability iscongenital. To make capable…Rehabilitatio...
BackgroundAfter a budget cut reduced state finances inAlabama, a staff reduction was implementedat the Bryce State Hospita...
Background… ofA class action lawsuit was brought on behalfRicky Wyatt by his aunt and guardian against theState of Alabama...
Background   Additional defendants in the case:       Agnes Baggett, Treasurer - State of Alabama       Roy Sanders, Co...
Issues   Were the 8th Amendment rights of    residents at State Hospital being    violated?   Were unavailability of fun...
Applicable Law       8th Amendment “Excessive bail shall not be  required, nor excessive finesimposed, nor cruel and unusu...
Arguments   Plaintiffs argued that the residents at    State Hospital had committed no crime, yet    were living in an in...
Holding   The 8th Amendment rights of individuals residing    in the State Hospital had been violated. They had    commit...
Dicta   Court found the defendants’ treatment    program deficient in 3 areas in that it failed    to provide:       Hum...
Dicta: Other Rights   Visitation & telephone communications as patients    at other public hospitals   Unrestricted righ...
Court’s Orders   The State of Alabama was ordered to restore    funding to State Hospital and reinstate staff to    appro...
Court’s Orders   Defendant’s would be allowed 6 months in    which to raise the level of care at Bryce    Hospital to a r...
Implications for Special                Education Policy   Idea of right to treatment &    individualized treatment plans...
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Wyatt v. stickney 1970

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  • Cruel and Unusual Punishment\n
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  • Habilitation facility- develop compensatory skills\n\nRehabilitation facility- maybe wasnt born that way, but became that way\n
  • Movie- ONe flew over the coocoos nest\n
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  • They are getting less than what other people are getting because they have MR\n\n
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  • 50 people confined in a small area- \nclose supervision\ngroup treatment-shower, restroom, etc\n\nno qualified staff\n\n
  • Therefore necessary to.....(see above)\n
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  • Cannot argue financial burden to the cost of these patients in these facilities or in special education.\n\n\n
  • Wyatt v. stickney 1970

    1. 1. Wyatt v. Stickney: Testing the 8 thAmendment & the Right to Treatment Sherwood Best, Ph.D. Professor, CSULA EDSP 501 1
    2. 2. Wyatt v. Stickney 325 F. Supp 781(Middle District of Alabama 1971) 344 F. Supp 373(Middle District of Alabama, 1972) Filed October 23, 1970 Decided April 13, 1972 2
    3. 3. TerminologyHabilitation– Treatment provision forindividuals whose disability iscongenital. To make capable…Rehabilitation – Treatment provisionfor individuals who experiencedisability after injury or illness; torestore to former capacity… 3
    4. 4. BackgroundAfter a budget cut reduced state finances inAlabama, a staff reduction was implementedat the Bryce State Hospital in Tuscaloosafor persons with mental illness. As aresult of that cut and subsequent staffreduction, hospital residents experienced asharp decline in habilitative services.Residents who exhibited non-compliant andaggressive behavior began to receiveincreased amounts of medication andeven physical restraint in order to “protect”themselves and other residents. 4
    5. 5. Background… ofA class action lawsuit was brought on behalfRicky Wyatt by his aunt and guardian against theState of Alabama and Stonewall B. Stickney,Commissioner of Mental Health and the State ofAlabama Mental Health Officer in which it wasalleged that the residents in the institutions werebeing subjected to cruel & unusualpunishment – a situation prohibited by the 8thAmendment.In 1971, the class was enlarged to include patientswith mental illness & mental retardation in otherstate institutions in Alabama. 5
    6. 6. Background Additional defendants in the case:  Agnes Baggett, Treasurer - State of Alabama  Roy Sanders, Comptroller - State of Alabama  Ruben King, Commissioner of Pensions & Security  George Wallace, Chairmen of Alabama State Board of Pensions & Security  James Bailey, as a representative member of the Alabama State Board of Pensions & Security  Stanley Frazer, Director of Alabama State Personnel Board 6
    7. 7. Issues Were the 8th Amendment rights of residents at State Hospital being violated? Were unavailability of funds, staff, & facilities adequate justification by the defendants to default in provision of suitable treatment for the mentally ill? 7
    8. 8. Applicable Law 8th Amendment “Excessive bail shall not be required, nor excessive finesimposed, nor cruel and unusual punishment inflicted.” 8
    9. 9. Arguments Plaintiffs argued that the residents at State Hospital had committed no crime, yet were living in an institution where they were deprived of habilitation. Therefore, their “incarceration” = penal confinement. Defendants argued that budget cutbacks necessitated measures to protect the residents from themselves and others, even if that protection involved chemical and physical restraint. 9
    10. 10. Holding The 8th Amendment rights of individuals residing in the State Hospital had been violated. They had committed no crime, and were therefore entitled to all appropriate and necessary habilitation services. Committed patients “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.” 10
    11. 11. Dicta Court found the defendants’ treatment program deficient in 3 areas in that it failed to provide:  Humane psychological/physical environment  Qualified staff in numbers sufficient to administer adequate treatment  Individualized treatment plans Additional considerations included:  Nontherapeutic work assignments  Absence of any semblance of privacy  Dangerous resident overcrowding & emergency hazards 11
    12. 12. Dicta: Other Rights Visitation & telephone communications as patients at other public hospitals Unrestricted right to send sealed mail Free from unnecessary/excessive medication Free from unnecessary restraint & isolation Not be subjected to experimental research without express & informed consent Not to be subjected to lobotomy, electro-convulsive treatment, adversive reinforcement conditioning without express & informed consent Suitable opportunities for interaction with members of the opposite sex Worship Physical exercise & regular time outdoors 12
    13. 13. Court’s Orders The State of Alabama was ordered to restore funding to State Hospital and reinstate staff to appropriate levels to ensure habilitation. Mental Health Board of Alabama was directed to sell or encumber land holdings to raise funds to implement toe Court’s orders. Emergency procedures were implemented to hire physicians to examine existing resident drug programs. 13
    14. 14. Court’s Orders Defendant’s would be allowed 6 months in which to raise the level of care at Bryce Hospital to a required minimum. Defendants were ordered to file reports defining the hospital’s mission and function, specifying the standards required to furnish treatment to the residents, and detailing the hospital’s progress toward implementation of these standards. 14
    15. 15. Implications for Special Education Policy Idea of right to treatment & individualized treatment plans evolved from the Wyatt case. A spotlight on state institutions for persons with mental illness and/or retardation led to public recognition of substandard care in many residential institutions. Deinstitutionalization of state facilities & re- location of residents to community-based facilities (and into public schools). 15
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