Mills v. Rogers, 457 U.S. 291 (1982)

Mills v. Rogers

No. 80-1417

Argued January 13, 1982
Decided June 18, 1982
457 U.S. 291

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR

THE FIRST CIRCUIT

Syllabus

Respondents, present or former mental patients at a Massachusetts state hospital, instituted a class action against petitioner officials and staff of the hospital in Federal District Court, alleging that forcible administration of antipsychotic drugs to patients violated rights protected by the Federal Constitution. The court held that mental patients enjoy constitutionally protected liberty and privacy interests in deciding for themselves whether to submit to drug therapy; that, under state law, an involuntary commitment provides no basis for an inference of legal "incompetency" to make such decision; and that, without consent either by the patient or the guardian of a patient who has been adjudicated incompetent, the patient’s liberty interests may be overridden only in an emergency. The Court of Appeals affirmed in part and reversed in part. It agreed with the District Court’s first two holdings above, but reached different conclusions as to the circumstances under which state interests might override the patient’s liberty interests. The Court of Appeals reserved to the District Court, on remand, the task of developing mechanisms to ensure adequate procedural protection of the patient’s interests. This Court granted certiorari to determine whether an involuntarily committed mental patient has a constitutional right to refuse treatment with antipsychotic drugs. Shortly thereafter, the Massachusetts Supreme Judicial Court ruled on the rights -- under both Massachusetts common law and the Federal Constitution -- of a nonintitutionalized incompetent mental patient as to involuntary treatment with antipsychotic drugs.

Held: The Court of Appeals’ judgment is vacated, and the case is remanded for that court’s consideration, in the first instance, of whether the correct disposition of this case is affected by the Massachusetts Supreme Judicial Court’s intervening decision. Pp. 298-306.

(a) Assuming (as the parties agree) that the Constitution recognizes a liberty interest in avoiding the unwanted administration of antipsychotic drugs, a substantive issue remains as to the definition of that protected constitutional interest, as well as identification of the conditions under which competing state interests might outweigh it. There is also a procedural issue concerning the minimum procedures required by the Constitution for determining that an individual’s liberty interest actually is outweighed in a particular instance. As a practical matter, both issues are intertwined with questions of state law, which may create liberty interests and procedural protections broader than those protected by the Federal Constitution. If so, the minimal requirements of the Federal Constitution would not be controlling, and would not need to be identified in order to determine the legal rights and duties of persons within the State. Pp. 298-300.

(b) While the record is unclear as to respondents’ position in the District Court concerning the effect of state law on their asserted federal rights, in their brief in this Court, they clearly assert state law arguments as alternative grounds for affirming both the "substantive" and "procedural" decisions of the Court of Appeals. In applying the policy of avoiding unnecessary decisions of constitutional issues, it is not clear which, if any, constitutional issues now must be decided to resolve the controversy between the parties. Because of its greater familiarity both with the record and with Massachusetts law, the Court of Appeals is better situated than this Court to determine how the intervening state court decision may have changed the law of Massachusetts and how any changes may affect this case. Pp. 304-306.

634 F.2d 650, vacated and remanded.

POWELL, J., delivered the opinion for a unanimous Court.