Parham v. J.R.

442 U.S. 584 (1979)

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Nature of the Case

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Facts

J.L. (P) was a minor child being treated in a Georgia state mental health hospital. P was part of a class action suit under 42 U.S.C. §1983. P sought a declaratory judgment that Georgia's voluntary commitment procedures for children under 18 violated Due Process and requested an injunction against enforcement. P was admitted at the age of six and prior to his admission had received outpatient treatment at the hospital for over two months. P's mother requested that he be admitted indefinitely. That was done, but after two years, the child was returned to the mother and stepfather and would attend school at the hospital on a furlough program. Eventually, the child was readmitted, and the parents relinquished their parental rights to the county. In 1975, P sued for an order of the court to place him in a less drastic environment suitable to his needs. J.R. (P2) was borderline retarded and suffered from unsocialized aggressive reaction to childhood. Unsuccessful efforts were made to find P2 a foster home. The District Court determined that commitment implicates a child's liberty interests and that the process due 'includes at least the right after notice to be heard before an impartial tribunal.' It required an adversary hearing. The inexactness of psychiatry, coupled with the possibility that the sources of information used to make the commitment decision may not always be reliable, made such a decision imperative. The District Court ordered the State to appropriate and expend such resources as would be necessary to provide nonhospital treatment to those members of P's class who would benefit from it. Eventually, the Supreme Court granted certiorari.