Filed Date: Jan. 1, 1986
Closed Date: Dec. 15, 1992
Clearinghouse coding complete
The Behavioral Research Institute (BRI), now know as the Judge Rotenberg Educational Center, is a Massachusetts based residential care facility for children and young adults with severe autism associated with behavioral problems. BRI is known for its use of negative reinforcement also known as aversive treatments, such as electric shock therapies, to disincentives undesirable behavior. As a result of its use of aversive treatments, BRI has been controversial and the subject of several law suits. This case, along with Judge Rotenberg Educational Center, Inc. v. Commissioner of the Department of Mental Retardation, Behavioral Research Institute v. Secretary of Administration, and Judge Rotenburg Center v. Food and Drug Administration, are some of the cases brought surrounding various issues related to BRI.
Two wards with disabilities housed at BRI filed a lawsuit in the Probate and Family Court of Bristol County, Massachusetts petitioning the Court for a writ of habeas corpus. The petitioners claimed that they were being unjustly deprived of their liberty without due process of law in violation of state statutes. The petitioners requested that they be placed somewhere other than BRI. The Probate and Family Court denied the petition for habeas corpus and the petitioners appealed.
On December 15, 1992, the Supreme Judicial Court of Massachusetts upheld the decision of the Probate and Family court to deny the petitions for habeas corpus. The Court held that the petitions failed because habeas corpus is not a means of requesting alternative placements but rather is to contest unjust restraint on liberty. Since the petitioners were merely requesting an alternative placement and were not contesting their general restraint on liberty or any underlying decisions, the petitions were denied. Petition of Kaufman 413 Mass 1010 (1992).
Summary Authors
Brian Kempfer (9/25/2014)
Haleigh Knowles (4/13/2026)
Behavioral Research Institute v. Secretary of Administration, Massachusetts state trial court (1989)
Abrams, Ruth (Massachusetts)
Greaney, John M. (Massachusetts)
Liacos, Paul J (Massachusetts)
Lynch, Neil L. (Massachusetts)
Nolan, Joseph R. (Massachusetts)
Last updated Aug. 30, 2023, 1:55 p.m.
Docket sheet not available via the Clearinghouse.State / Territory:
Case Type(s):
Intellectual Disability (Facility)
Key Dates
Filing Date: Jan. 1, 1986
Closing Date: Dec. 15, 1992
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Two students with severe autism and mental impairments who are residents at a residential school
Plaintiff Type(s):
Public Interest Lawyer: Unknown
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Private Entity/Person
Judge Rotenberg Educational Center
Facility Type(s):
Case Details
Causes of Action:
Other Dockets:
Massachusetts state supreme court 86E-0018-G1
Available Documents:
Outcome
Prevailing Party: Defendant
Relief Sought:
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Issues
General/Misc.:
Disability and Disability Rights:
Intellectual/developmental disability, unspecified
Discrimination Basis:
Disability (inc. reasonable accommodations)
Jails, Prisons, Detention Centers, and Other Institutions:
Assault/abuse by staff (facilities)
Deinstitutionalization/decarceration
Placement in mental health facilities
Case Summary of Petition of Kaufman, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/14079/ (last updated 4/13/2026).