Case: Eckerhart v. Hensley

2:75-cv-00087 | U.S. District Court for the Western District of Missouri

Filed Date: April 14, 1975

Closed Date: June 30, 1983

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Case Summary

In 1975, a class action lawsuit was filed on behalf of all people involuntarily confined at the Forensic Unit of the Fulton State Hospital in the United States District Court for the Western District of Missouri against the Missouri Mental Health Commission and officials responsible for the operation of the Forensic Unit. The plaintiffs, represented by the Legal Aid Society of St. Louis, sought injunctive and declaratory relief alleging that (1) the conditions in the Forensic Unit fell below c…

In 1975, a class action lawsuit was filed on behalf of all people involuntarily confined at the Forensic Unit of the Fulton State Hospital in the United States District Court for the Western District of Missouri against the Missouri Mental Health Commission and officials responsible for the operation of the Forensic Unit. The plaintiffs, represented by the Legal Aid Society of St. Louis, sought injunctive and declaratory relief alleging that (1) the conditions in the Forensic Unit fell below constitutional minimum standards, and (2) that patients were placed in the unit's maximum-security facility, the Marion O. Briggs Building for the Criminally Insane, without due process of law. The plaintiffs also sought compensation for work performed for the institution by patients.

In December 1973, the parties entered into a consent decree which resolved the due process complaint. In August 1974, Missouri began to compensate patients for their labor in accordance with the Fair Labor Standards Act, 28 U.S.C. § 201 et seq., which led the plaintiffs to drop their wage claims in July 1976. In August 1977, the plaintiffs filed an amended complaint in which they delineated six specific aspects of confinement at Fulton State Hospital that violated the U.S. Constitution. Specifically, the plaintiffs' allegations addressed (1) the physical environment, which was drably decorated and afforded little visual stimulation and privacy, (2) individualized treatment plans, which were not consistently in place, (3) the right to be placed in the least restrictive environment, which was impaired by long waiting lists for transfer out of the Briggs Building, (4) seclusion and restraint, which were allegedly used punitively in conflict with Missouri policies, (5) restrictive visitation, telephone and mail policies, which effectively isolated patients from their friends and families and denied them access to attorneys, and (6) staff numbers and qualifications, which were insufficient to deliver therapeutic services.

On August 11, 1979, the United States District Court for the Western District of Missouri (Judge Elmo B. Hunter) ordered improvements in all areas except staff ratios and training. Eckerhart v. Hensley, 475 F. Supp. 908 (W.D. Mo. 1979). Although the court noted that employing a greater number of qualified staff would benefit patients in the Forensic Unit, the court held that the facility's poor staff-to-patient ratios did not reach to the level of a constitutional violation because therapeutic treatment was still possible. However, the court held that the right to therapeutic treatment and constitutional minimums were not met by (1) the drab physical environment, (2) the exceptional delay between new patient intake and development of an individualized plan, (3) long waiting lists for transferring out of the Briggs Building, (4) disciplining patients with physical restraints and seclusion in contravention of state policy, and (5) rigid visitation, telephone, and mail restrictions.

On January 23, 1981, the court deemed the plaintiffs to be the prevailing party, despite the fact that some of their claims were unsuccessful, and granted the plaintiffs attorney's fees and costs. On September 28, 1981, the United States Court of Appeals for the Eighth Circuit affirmed the district court's award. Eckerhart v. Hensley, 664 F.2d 294 (8th Cir. 1981). The defendants appealed and, on March 1, 1982, the United States Supreme Court granted certiorari. Hensley v. Eckerhart, 455 U.S. 988 (1982).

On May 16, 1983, the Supreme Court (Justice Lewis F. Powell, Jr.) vacated the ruling and remanded the case for proceedings consistent with the judgment. Hensley v. Eckerhart, 461 U.S. 424 (1983). The Court held that the prevailing party was entitled to an award of attorney's fees proportionate to the relief granted for successful claims. Thus, attorney's fees should be reduced when a party engages in litigation that is not entirely successful. Justice Warren E. Burger concurred, construing the majority opinion as requiring a detailed accounting of time spent on litigation when attorney's fees are sought under 42 U.S.C. § 1988. Justice William J. Brennan, Jr. in dissent argued that the district court's award was consistent with the intent and purpose of 42 U.S.C. § 1988, specifically to encourage enforcement of civil rights legislation. The dissent also argued that vacating the award was unnecessary because the majority's analysis would produce the same award amount. The Eighth Circuit vacated the district court's judgment on June 30, 1983. Eckerhart v. Hensley, 716 F.2d 909 (8th Cir. 1983). The case now appears closed.

Summary Authors

Elizabeth Chilcoat (6/29/2006)

Nick Kabat (10/28/2014)

People


Judge(s)

Burger, Warren Earl (District of Columbia)

Hunter, Elmo Bolton (Missouri)

Powell, Lewis Franklin Jr. (District of Columbia)

Attorneys(s) for Plaintiff

Bastian, Michael P. (Missouri)

Berkowitz, Stuart R. (Missouri)

Carlson, Ronald L. (Missouri)

Attorneys(s) for Defendant

Arnet, William F. (Missouri)

Boicourt, Michael L. (Missouri)

Eichner, Stanley J. (Missouri)

Lever, Ann D. (Missouri)

Judge(s)

Burger, Warren Earl (District of Columbia)

Hunter, Elmo Bolton (Missouri)

Powell, Lewis Franklin Jr. (District of Columbia)

Attorneys(s) for Plaintiff

Bastian, Michael P. (Missouri)

Berkowitz, Stuart R. (Missouri)

Carlson, Ronald L. (Missouri)

Attorneys(s) for Defendant

Arnet, William F. (Missouri)

Boicourt, Michael L. (Missouri)

Eichner, Stanley J. (Missouri)

Lever, Ann D. (Missouri)

Documents in the Clearinghouse

Document

Opinion

475 F.Supp. 908

Aug. 11, 1979 Order/Opinion

Opinion

U. S. Court of Appeals for the Eighth Circuit

664 F.2d 294

Sept. 28, 1981 Order/Opinion

Ruling on Petition for Writ of Certiorari

Hensley v. Eckerhart

Supreme Court of the United States

455 U.S. 988, 102 S.Ct. 1610, 71 L.Ed.2d 847

March 1, 1982 Order/Opinion

Opinion

Hensley v. Eckerhart

Supreme Court of the United States

461 U.S. 424, 103 S.Ct. 1933, 76 L.Ed.2d 40

May 16, 1983 Order/Opinion

Opinion

U. S. Court of Appeals for the Eighth Circuit

716 F.2d 909

June 30, 1983 Order/Opinion

Resources

Title Description External URL

The Oyez Project, Hensley v Eckerhart, 461 U.S. 424 (1983)

Oyez Project

Information about the Supreme Court litigation in this case, including an audio recording of the oral argument, and the written opinion. May 16, 1983 http://www.oyez.org/cases/1980-1989/1982/1982_81_1244/

The Oyez Project, Hensley v. Eckerhart, 461 U.S. 424 (1983).

Oyez Project

Information about the Supreme Court litigation in this case, including an audio recording of the oral argument, and the written opinion. May 16, 1983 http://www.oyez.org/cases/1980-1989/1982/1982_81_1244/

The Effects of Hensley v. Eckerhart on the Award of Attorney's Fees

E. Wayne Powell

Under the American rule,' prevailing litigants in the United States traditionally have not been entitled to collect attorney's fees from the unsuccessful party. However, Congress has enacted fee-shif… https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=1262&context=ulj

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: Missouri

Case Type(s):

Mental Health (Facility)

Key Dates

Filing Date: April 14, 1975

Closing Date: June 30, 1983

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Involuntarily confined patients at the Forensic Unit of the Fulton State Hospital.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

NDRN/Protection & Advocacy Organizations

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

State Department of Health and Human Services (Fulton), State

Defendant Type(s):

Hospital/Health Department

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Availably Documents:

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Attorneys fees

Source of Relief:

Settlement

Litigation

Order Duration: 1979 - 1983

Issues

General:

Access to lawyers or judicial system

Bathrooms

Conditions of confinement

Confinement/isolation

Individualized planning

Restraints : physical

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Totality of conditions

Visiting

Wait lists

Work release or work assignments

Disability:

Least restrictive environment

Medical/Mental Health:

Mental health care, general

Type of Facility:

Government-run