Kesselbrenner v. Anonymous, 33 N.Y.2d 161 (1973)
Civilly committed mental patients, not charged with any crime, cannot be confined in a correctional facility primarily for mentally ill convicted criminals because such confinement violates due process if a less restrictive alternative is available.
Summary
This case concerns the constitutionality of a New York law that mandated the transfer of dangerously mentally ill patients from civil state hospitals to Matteawan State Hospital, a correctional facility for mentally ill criminals. The New York Court of Appeals held that confining a civilly committed patient in a correctional facility, when less restrictive alternatives exist, violates due process. The court reasoned that the nature of confinement must bear a reasonable relationship to its purpose, and that incarcerating a non-criminal in a prison-like environment is punitive rather than therapeutic.
Facts
The appellant, a patient at Manhattan State Hospital, had a history of admissions and unprovoked assaults. Two physicians certified him as “dangerously mentally ill” under Section 85 of the Mental Hygiene Law. The hospital director sought a court order to transfer him to Matteawan State Hospital. The appellant was diagnosed with chronic undifferentiated schizophrenia, exhibiting delusions and hallucinations. Although some doctors believed his condition could improve with treatment, all agreed on his current dangerousness and need for secure confinement.
Procedural History
The Supreme Court, Special Term, found the appellant dangerously mentally ill but refused to commit him to Matteawan, deeming the statute unconstitutional. The Appellate Division reversed, ordering commitment to a Department of Correction facility. The New York Court of Appeals then reversed the Appellate Division, reinstating the Supreme Court’s order.
Issue(s)
Whether the mandatory transfer of a dangerously mentally ill civil patient to a correctional facility like Matteawan, when less restrictive alternatives exist, violates the Due Process Clause of the Fourteenth Amendment?
Holding
Yes, because subjecting a person to a greater deprivation of personal liberty than necessary to achieve the purpose for which they are being confined violates due process. Confinement must be therapeutic, not punitive, and incarceration in a penal facility is incompatible with this purpose when suitable alternatives are available.
Court’s Reasoning
The court emphasized that due process requires the nature and duration of commitment to bear a reasonable relationship to its purpose, citing Jackson v. Indiana. It reasoned that confining a non-criminal in Matteawan, a correctional facility, is punitive and not therapeutic. The court highlighted the differences between hospitals under the Department of Mental Hygiene, which prioritize care, treatment, and rehabilitation, and Matteawan, a security-oriented institution primarily for mentally ill criminals. The court noted the greater restrictions on freedom of movement, correspondence, and visitors in Matteawan. The court also noted the existence of less restrictive alternatives, such as closed wards in other state hospitals. The court quoted Matter of Ellery C., noting the hazard of the patient emerging “well tutored in the ways of crime.” It stated that a “continuing failure to provide suitable and adequate treatment cannot be justified by lack of staff or facilities,” citing Rouse v. Cameron. Ultimately, the court found no way to construe Section 85 to preserve its constitutionality given the absence of alternatives to Matteawan. The court acknowledged the petitioner’s concern about funding but asserted that this deficiency does not justify transferring the appellant to Matteawan. The court dismissed the petitioner’s reliance on Baxstrom v. Herold, stating that the propriety of commitment of a dangerously mentally ill patient to a Department of Correction institution was entirely peripheral to either court’s decision. It also dismissed appellant’s equal protection argument.