Rivers v. Katz, 67 N.Y.2d 485 (1986)
Involuntarily committed mental patients have a fundamental right under the New York State Constitution to refuse antipsychotic medication, which can only be overridden by a judicial determination of incapacity to make a reasoned decision, or in emergency situations under the state’s police power.
Summary
Rivers, Zatz, and Grassi, involuntarily committed patients, challenged the nonconsensual administration of antipsychotic drugs. The New York Court of Appeals held that involuntarily committed mental patients possess a fundamental right to refuse antipsychotic medication under the state constitution’s due process clause. This right is not absolute but can be overridden if the patient is deemed incapable of making a reasoned decision about treatment or if the State’s police power is implicated due to the patient’s dangerousness. The court mandated a judicial hearing to determine the patient’s capacity to make treatment decisions, placing the burden on the state to prove incapacity by clear and convincing evidence.
Facts
Mark Rivers, Florence Zatz, and Florence Grassi were involuntarily committed to Harlem Valley Psychiatric Center. Each had been deemed in need of involuntary care and treatment due to mental illness impairing their judgment. Rivers and Zatz were medicated with antipsychotic drugs after refusing treatment and undergoing administrative review where their objections were overruled. Grassi was similarly medicated after refusing and having her protest overruled. All three patients then initiated legal challenges to stop the forced medication.
Procedural History
Rivers and Zatz filed a declaratory judgment action, which was dismissed by Special Term, which was affirmed by the Appellate Division. Grassi filed an Article 78 proceeding, also dismissed for similar reasons. The Appellate Division consolidated the appeals and affirmed the lower court’s decisions. The New York Court of Appeals reversed, holding that the patients had a right to refuse medication under the state constitution.
Issue(s)
Whether involuntarily committed mental patients have a constitutional right to refuse antipsychotic medication, and if so, under what circumstances can that right be overridden?
Holding
Yes, involuntarily committed mental patients have a fundamental right to refuse antipsychotic medication because this right is coextensive with the patient’s liberty interest protected by the due process clause of the New York State Constitution. This right can be overridden only if the patient is judicially determined to lack the capacity to make a reasoned decision about treatment or if the State’s police power is implicated due to the patient’s dangerousness.
Court’s Reasoning
The court grounded its decision in the common-law right of individuals to control their medical treatment, a right that extends to mentally ill persons. It rejected the argument that involuntary commitment automatically implies incompetence to make treatment decisions. The court acknowledged that this right is not absolute and may yield to compelling state interests under the police power (e.g., imminent danger to self or others) or the parens patriae power (protecting those unable to care for themselves). However, the parens patriae power can only be invoked after a judicial determination that the patient lacks the capacity to make a reasoned treatment decision.
The court emphasized the need for procedural safeguards, including a de novo judicial hearing with representation by counsel, where the State bears the burden of proving incapacity by clear and convincing evidence. If incapacity is established, the court must then determine whether the proposed treatment is narrowly tailored to the patient’s best interests, considering benefits, side effects, and less intrusive alternatives.
The court found the existing administrative review procedures inadequate to protect patients’ due process rights, citing the lack of clear standards and criteria. It also emphasized that medical determinations must adhere to accepted professional judgment and standards.
Quoting the Oklahoma Supreme Court, the court stated, “[i]f the law recognizes the right of an individual to make decisions about * * * life out of respect for the dignity and autonomy of the individual, that interest is no less significant when the individual is mentally or physically ill”.
The court concluded that “neither mental illness nor institutionalization per se can stand as a justification for overriding an individual’s fundamental right to refuse antipsychotic medication on either police power or parens patriae grounds.”