Case: Wyatt v. Stickney

On October 23, 1970, patients involuntarily confined for mental treatment purposes at Bryce Hospital in Tuscaloosa, Alabama, filed a class action lawsuit under 42 U.S.C. § 1983 against the Alabama Department of Mental Health and Mental Retardation (DMH/MR) in the U.S. District Court for the Middle District of Alabama, Northern Division. The plaintiffs, represented by the American Civil Liberties Union and private counsel, asked the court for declaratory and injunctive relief, alleging that conditions at facilities operated by DMH/MR violated residents' rights under state and federal law.

In the 33-year span of this litigation, this case became one of the most celebrated mental health cases.

On March 12, 1971, the District Court (Judge Frank M. Johnson, Jr.) held that the patients were being denied their right to treatment and granted the defendants six months in which to raise the level of care at Bryce. Wyatt v. Stickney, 325 F. Supp. 781 (M.D. Ala. 1971). Judge Johnson reasoned that involuntarily 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 in to improve his or her mental condition." On August 12, 1971, Judge Johnson enlarged the plaintiff class to include patients involuntarily confined at Searcy Hospital and at Partlow State School and Hospital. After the defendants filed their final report, on December 10, 1971, Judge Johnson concluded that the treatment program was deficient for failing to provide (a) a humane psychological and physical environment, (b) qualified staff in number sufficient to administer adequate treatment, and (c) individualized treatment plans. Wyatt v. Stickney, 334 F. Supp. 1341 (M.D. Ala. 1971).

On April 13, 1972, the District Court (Judge Johnson) filed two opinions. In the first, Judge Johnson concluded that the plaintiffs had been denied the right of habilitation, and ordered that minimum standards had to be effectuated at the institutions immediately. Wyatt v. Stickney, 344 F. Supp. 387 (M.D. Ala. 1972). In the second, Judge Johnson issued orders establishing minimal constitutional standards for treatment of persons with mental illness and persons with intellectual disabilities. Wyatt v. Stickney, 344 F. Supp. 373 (M.D. Ala. 1972). The defendants appealed.

On November 8, 1974, the Fifth Circuit Court of Appeals (Judge John Minor Wisdom) affirmed in relevant part the District Court's April 13, 1972, decisions. Wyatt v. Aderholt, 503 F.2d 1305 (5th Cir. 1974).

In June 1977, the plaintiffs succeeded in obtaining a federal court office to monitor compliance with the Wyatt standards. And on January 15, 1980, the District Court (Judge unknown) entered an order placing DMH/MR in receivership.

The parties engaged in extended negotiations and, in 1986, the parties entered into a consent decree requiring all state facilities to achieve JCAHO accreditation and Title XIX certification. On September 22, 1986, the District Court (Judge Myron H. Thompson) approved the consent decree. Wyatt v. Wallis, No. 3195-N, 1986 WL 69194 (M.D. Ala. Sept. 22, 1986). Under the consent decree, DMH/MR was required to make substantial progress in outplacing persons from state facilities, as well as to develop a system of internal advocacy and quality assurance of care.

Judge Thompson subsequently approved further consent decrees that clarified the licensing requirements, development of treatment plans, supervision of treatment at state mental health facilities, creation and modification of an expert panel, and allowed further plaintiffs to intervene. Wyatt v. Horsley, No. 3195-N (M.D. Ala. July 2, 1991); Wyatt v. King, No. 3195-N (M.D. Ala. Oct. 25, 1991); Wyatt v. King, 793 F. Supp. 1058 (M.D. Ala. 1992).

On July 22, 1991, the District Court found that Alabama's indefinite institutionalization of the involuntarily civilly committed was unconstitutional and ordered the defendants to conduct periodic post-commitment judicial reviews under certain standards. Wyatt v. King, 773 F. Supp. 1508 (M.D. Ala. 1991).

On January 23, 1993, the plaintiffs moved to enforce the 1986 consent decree, claiming that DMH/MR had failed to comply with the 1986 decree and was violating the recently enacted Americans with Disabilities Act of 1990. And on December 22, 1994, the District Court (Judge Thompson) recertified the plaintiff class.

After a 35-day summary proceeding, on July 11, 1995, the District Court (Judge Thompson) granted the plaintiffs' motion for a preliminary injunction and denied the defendants' motions to disqualify the judge and to decertify the class. Wyatt v. Rogers, 892 F. Supp. 1410 (M.D. Ala. 1995). The defendants appealed. Judge Thompson held that the injunction was warranted to correct DMH/MR's failure to deal the gang activity, physical and sexual abuse on the part of staff, as well as use of improper methods to restrain children. The defendants appealed.

On August 8, 1996, the Eleventh Circuit Court of Appeals (Judge Gerald Bald Tjoflat) dismissed the appeal. Wyatt v. Rogers, 92 F.3d 1074 (11th Cir. 1996). The Court held that the appeal was rendered moot since the facility was closed during the pendency of the appeal, negating the court's jurisdiction. The Court also set forth procedures the plaintiffs had to follow in order to obtain DMH/MR's compliance with the decree.

On October 8, 1996, the District Court (Judge Thompson) denied the plaintiffs' motion for enforcement of the consent decree. Wyatt v. Rogers, 942 F. Supp. 518 (M.D. Ala. 1996). Judge Thompson found that the plaintiffs failed to follow the procedures set forth by the Eleventh Circuit, and that plaintiffs' procedural failures precluded enforcement under the consent decree.

Subsequently, DMH/MR moved for a finding that DMH/MR had sufficiently complied with the consent decree, allowing the lawsuit to be terminated. On December 15, 1997, the District Court (Judge Thompson) granted the defendants partial release from those provisions of the consent decree with which DMH/MR had complied, and denied the plaintiffs' motion for relief other than under the 1986 consent decree. Wyatt v. Rogers, 985 F. Supp. 1356 (M.D. Ala. 1997). Analyzing the case as a whole, Judge Thompson broke the Wyatt litigation up into four phases: (1) the establishment and extension of the Wyatt standards in the early 1970's; (2) the resumption of litigation in 1975, subsequent receivership and plan of compliance; (3) the resumption of litigation in 1981 resulting in the negotiation of the consent decree, establishment the Wyatt Consultant Committee and subsequent termination of the Consultant Committee; and, (4) the resumption of litigation in 1991, intervention of further plaintiffs, defendants' motions to dismiss and plaintiffs' motions to enforce. Judge Thompson recognized 31 current Wyatt mental-illness standards, organized and addressed them by category: (1) physical living environment and custodial care; (2) personal liberties; (3) treatment and record keeping; (4) medical care; (5) use and administration of psychotropic medications; (6) protection from harm and physical safety; (7) adequate staffing and staff supervision; (8) high risk or unusually restrictive treatment; (9) seclusion and restraint; (10) treatment in the least restrictive environment appropriate and transitional services; and (11) children's services. Judge Thompson found that DMH/MR was not in compliance with Wyatt standards concerning privacy and dignity, least restrictive conditions, visitation rights, freedom from unnecessary medication, freedom from seclusion/physical restraint, physical exercise, outdoors at regular intervals, religion, human environment facilities, supervision of staff, patient treatment, individualized treatment plans, confidentiality of records, transitional treatment post-release and written notice. And Judge Thompson continued the Court's oversight of DMH/MR's compliance with those standards.

In line with the District Court's request that the parties narrow the issues still in contention, on December 9, 1998, the District Court (Judge Thompson) granted the parties' joint motion to release a list of facilities from the consent decree. Wyatt v. Rogers, No. Civ.A. 3195-N, 1998 WL 862920 (M.D. Ala. Dec. 9, 1998).

On October 1, 2000, the parties entered into a three-year settlement agreement. Under the settlement agreement, the Commissioner established work groups to develop compliance plans. And after a fairness hearing to consider a joint motion of compliance with the settlement agreement, on December 5, 2003, the District Court (Judge Thompson) terminated the lawsuit.

There is an interesting video about the suit available here: https://mn.gov/mnddc/parallels2/one/video/wyatt.html