Parham v. J.R. (1979)

United States Supreme Court

442 U.S. 584

Nature of Case

Whether it was unconstitutional, according to the Due Process Clause of the 14th Amendment, to voluntary commit juveniles without a formal or quasi-formal hearing.

Facts of Case

Children being treated in Georgia state hospitals brought an action against Georgia mental health officials in the United States District Court for the Middle District of Georgia. They alleged that their Constitutional rights to due process were violated because they were not provided certain procedural protections under Georgia’s 1975 statute. They sought a declaratory judgment, alleging that the Georgia statute for the voluntary commitment of individuals under the age of 18 violated due process, because they were not afforded an adversarial hearing.

The District Court held that Georgia’s statutory scheme was unconstitutional, because it failed to protect the minors’ rights to due process. The district court indicated that “the process due included at least the right after notice to an adversary-type hearing before an impartial tribunal.” On direct appeal from the district court, The United States Supreme Court then heard the case to evaluate whether the Georgia statute was unconstitutional on due process grounds.

Issue

Did the district court err in concluding the Georgia statute violated due process rights, because it did not afford the minors an adversary-type hearing?

 

Holding

In an opinion delivered by Justice Burger, the Court reversed the decision of the district court and remanded for further proceedings. The Court found the Georgia statute did not violate due process rights of minors. The court held that due process does not require a formal or quasi-formal hearing prior to commitment; however, due to the “risk of error inherent in the parental decision to have a child institutionalized,” an inquiry by a neutral fact-finder to determine if statutory requirements have been met for admission, is required by due process. The Court identified that the minimum due process requirements for the voluntary commitment of minors includes the following:

  1. Inquiry by a “neutral factfinder” to include interviews with the child and parents, and an investigation of the child’s background using collateral sources, such as schools, social service agencies, and any additional sources available. The Court indicated that the neutral factfinder could be medical staff working at the hospital.
  2. The decision-maker must have the authority to refuse to admit a child who has not satisfied medical standards for admission, and once admitted, continuing need for commitment must be reviewed periodically by an independent procedure.
  3. When the child and parents are determined to be at odds in regard to commitment, the state can elect to provide adversary hearings, preceded by a written notice, at which a child is represented by counsel. However, nothing in the United States Constitution compels such procedures.

Rationale

The Court concluded that the Georgia statute satisfied minimum due process requirements, because an admissions team, composed of a psychiatrist and at least one other mental health professional examined and interviewed the child, in addition to reviewing medical records and interviewing parents. This team also made determinations concerning whether the children would benefit from institutionalized care and if conditions were not met, admission was refused. It was judged that the admission staff at the state hospitals had acted in a “neutral and detached fashion” in identifying the best interests of the children and in making their medical determinations.

In rejecting the contention that an adversarial hearing was required by due process, the Court stated that “common human experience and scholarly opinions suggest that the supposed protections of an adversary proceeding to determine the appropriateness of medical decisions for the commitment and treatment of mental and emotional illness may well be more illusory than real.” The Court also concluded that whether the petition for admission was initiated by the child’s natural parent, another guardian, or the state acting as guardian, the admission process could remain the same. The Court stated that it was a valid statutory presumption that the state was acting in the best interests of the child, and there was no evidence that the state attempted to admit children to the state hospitals for reasons unrelated to their need for treatment.

Further the Court stated “the complex of procedures ordered by the District Court…are unnecessary to protect the child’s rights, they divert public resources from the central objective of administering health care, they risk aggravating the tensions inherent in the family situation, and they erect barriers that may discourage parents from seeking medical aid for a disturbed child.” The Court indicated that while the Georgia statute was not unconstitutional, the district court could consider, on remand, individual claims that initial admissions of specific children did not meet the due process standards. Additionally, the district court could review specific hospital procedures for periodic review, in order to justify whether these procedures for continuing a voluntary commitment met due process standards.Rich Text AreaToolbarBold (Ctrl + B)Italic (Ctrl + I)Strikethrough (Alt + Shift + D)Unordered list (Alt + Shift + U)Ordered list (Alt + Shift + O)Blockquote (Alt + Shift + Q)Align Left (Alt + Shift + L)Align Center (Alt + Shift + C)Align Right (Alt + Shift + R)Insert/edit link (Alt + Shift + A)Unlink (Alt + Shift + S)Insert More Tag (Alt + Shift + T)Proofread WritingToggle fullscreen mode (Alt + Shift + G)Show/Hide Kitchen Sink (Alt + Shift + Z)
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Parham v. J.R. (1979)
United States Supreme Court
442 U.S. 584
Nature of Case
Whether it was unconstitutional, according to the Due Process Clause of the 14th Amendment, to voluntary commit juveniles without a formal or quasi-formal hearing.

Facts of Case
Children being treated in Georgia state hospitals brought an action against Georgia mental health officials in the United States District Court for the Middle District of Georgia. They alleged that their Constitutional rights to due process were violated because they were not provided certain procedural protections under Georgia’s 1975 statute. They sought a declaratory judgment, alleging that the Georgia statute for the voluntary commitment of individuals under the age of 18 violated due process, because they were not afforded an adversarial hearing.
The District Court held that Georgia’s statutory scheme was unconstitutional, because it failed to protect the minors’ rights to due process. The district court indicated that “the process due included at least the right after notice to an adversary-type hearing before an impartial tribunal.” On direct appeal from the district court, The United States Supreme Court then heard the case to evaluate whether the Georgia statute was unconstitutional on due process grounds.
Issue
Did the district court err in concluding the Georgia statute violated due process rights, because it did not afford the minors an adversary-type hearing?

Holding
In an opinion delivered by Justice Burger, the Court reversed the decision of the district court and remanded for further proceedings. The Court found the Georgia statute did not violate due process rights of minors. The court held that due process does not require a formal or quasi-formal hearing prior to commitment; however, due to the “risk of error inherent in the parental decision to have a child institutionalized,” an inquiry by a neutral fact-finder to determine if statutory requirements have been met for admission, is required by due process. The Court identified that the minimum due process requirements for the voluntary commitment of minors includes the following:
Inquiry by a “neutral factfinder” to include interviews with the child and parents, and an investigation of the child’s background using collateral sources, such as schools, social service agencies, and any additional sources available. The Court indicated that the neutral factfinder could be medical staff working at the hospital.
The decision-maker must have the authority to refuse to admit a child who has not satisfied medical standards for admission, and once admitted, continuing need for commitment must be reviewed periodically by an independent procedure.
When the child and parents are determined to be at odds in regard to commitment, the state can elect to provide adversary hearings, preceded by a written notice, at which a child is represented by counsel. However, nothing in the United States Constitution compels such procedures.
Rationale
The Court concluded that the Georgia statute satisfied minimum due process requirements, because an admissions team, composed of a psychiatrist and at least one other mental health professional examined and interviewed the child, in addition to reviewing medical records and interviewing parents. This team also made determinations concerning whether the children would benefit from institutionalized care and if conditions were not met, admission was refused. It was judged that the admission staff at the state hospitals had acted in a “neutral and detached fashion” in identifying the best interests of the children and in making their medical determinations.
In rejecting the contention that an adversarial hearing was required by due process, the Court stated that “common human experience and scholarly opinions suggest that the supposed protections of an adversary proceeding to determine the appropriateness of medical decisions for the commitment and treatment of mental and emotional illness may well be more illusory than real.” The Court also concluded that whether the petition for admission was initiated by the child’s natural parent, another guardian, or the state acting as guardian, the admission process could remain the same. The Court stated that it was a valid statutory presumption that the state was acting in the best interests of the child, and there was no evidence that the state attempted to admit children to the state hospitals for reasons unrelated to their need for treatment.
Further the Court stated “the complex of procedures ordered by the District Court…are unnecessary to protect the child’s rights, they divert public resources from the central objective of administering health care, they risk aggravating the tensions inherent in the family situation, and they erect barriers that may discourage parents from seeking medical aid for a disturbed child.” The Court indicated that while the Georgia statute was not unconstitutional, the district court could consider, on remand, individual claims that initial admissions of specific children did not meet the due process standards. Additionally, the district court could review specific hospital procedures for periodic review, in order to justify whether these procedures for continuing a voluntary commitment met due process standards.
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