The Law School Authority

Youngberg v. Romeo Case Brief

Summary of Youngberg v. Romeo

Rule: The constitutional right to liberty of involuntarily committed, mentally retarded persons includes rights of adequate food, shelter, clothing, and medical care.  It also requires reasonably safe conditions, freedom from bodily restraint, and minimally adequate training to ensure these rights.  A medical professional’s judgment is sufficient to deem the elements satisfied.  

Facts: Mother was concerned about injustices her son had suffered.  Sued claiming that her son had the right to:

    1. safe conditions of confinement
    2. freedom from bodily restraint
    3. a constitutional right to minimally adequate habilitation (skills development)


      • The first two involve liberty interests and thus are protected. 
      • As for the third issue:
        1. one must balance the interests of the state and of the individual. 
        2. Persons who have been involuntarily committed deserve better treatment than a criminal but not so great a treatment that there has to be a compelling state interest to use restraints.
        3. Because the professionals believed this to be reasonable, we defer to that judgment. 

Blackmun concur: leaves two important questions unresolved:

    1. Whether the state could accept someone for care and treatment, and then deny treatment
    2. Whether P has a constitutional claim to training necessary to preserve skills already obtained

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