''Rennie v. Klein'', 462 F. Supp. 1131 (D.N.J. 1978), was a case heard in the
United States District Court for the District of New Jersey
The United States District Court for the District of New Jersey (in case citations, D.N.J.) is a federal court in the United States Court of Appeals for the Third Circuit, Third Circuit (except for patent claims and claims against the U.S. gover ...
in 1978 to decide whether an
involuntarily committed mental patient has a constitutional right to refuse
psychiatric medication
A psychiatric or psychotropic medication is a psychoactive drug taken to exert an effect on the chemical makeup of the brain and nervous system. Thus, these medications are used to treat mental illnesses. These medications are typically made of ...
. It was the first case to establish that such a patient has the right to refuse medication in the United States.
Circumstances
John Rennie, age 38, was a former pilot and flight instructor who was a patient at
Ancora Psychiatric Hospital in
Winslow Township, New Jersey. His case was brought in December 1977. Rennie's psychiatric history indicates that he did not show signs of
mental illness
A mental disorder, also referred to as a mental illness, a mental health condition, or a psychiatric disability, is a behavioral or mental pattern that causes significant distress or impairment of personal functioning. A mental disorder is ...
until he was 31. He was first hospitalized in 1973, and subsequently he was discharged and re-admitted many times, primarily, as trial judge Stanley Brotman noted, because of "his failure to continue taking medications after he has left the hospital's custody." He had been given various diagnoses over time including
paranoid schizophrenia and
manic-depressive psychosis. Rennie had persistent religious delusions (he thought he was
Christ
Jesus ( AD 30 or 33), also referred to as Jesus Christ, Jesus of Nazareth, and many other names and titles, was a 1st-century Jewish preacher and religious leader. He is the Jesus in Christianity, central figure of Christianity, the M ...
) and
suicidal ideation
Suicidal ideation, or suicidal thoughts, is the thought process of having ideas or ruminations about the possibility of dying by suicide.World Health Organization, ''ICD-11 for Mortality and Morbidity Statistics'', ver. 09/2020MB26.A Suicidal i ...
. His eighth hospitalization was initiated after he threatened to kill
President Ford. On subsequent hospitalizations he became increasingly abusive and assaultive.
In December 1977, during his twelfth hospitalization that began on August 10, 1976, doctors had unsuccessfully tried various psychiatric medications. Rennie sued in federal district court to prevent the hospital from administering
psychotropic
A psychoactive drug, psychopharmaceutical, mind-altering drug, consciousness-altering drug, psychoactive substance, or psychotropic substance is a chemical substance that alters psychological functioning by modulating central nervous system acti ...
medications to him without a clear emergency. His counsel was the
Office of the Public Advocate. As Judge Brotman describes in his decision, the precipitating factors occurred earlier in the month when Rennie had become homicidal. Hospital staff felt his condition was deteriorating; to prevent Rennie from harming other patients, staff, and himself, the treatment team administered
prolixin decanoate, an injectable long-acting drug, because of his history of failing to take medication once released. They believed the drug would be the easiest drug on which to maintain him after release. Following initiation of the prolixin regime, Rennie's condition did improve markedly.
Judge Brotman responded to Rennie's appeal for an injunction by issuing a compromise ruling. Rather than enjoining the hospital from giving him any medication, he insisted that the prolixin be lowered to a minimum maintenance dosage, which staff psychiatrists considered too low. He then conducted fourteen days of hearings between January 13 and April 28, 1978.
Several months after issuing his initial ruling that asserted a right to refuse treatment grounded in a constitutional
right to privacy
The right to privacy is an element of various legal traditions that intends to restrain governmental and private actions that threaten the privacy of individuals. Over 185 national constitutions mention the right to privacy.
Since the globa ...
, Judge Brotman made the case into a class action that included all involuntarily committed patients at the five mental health facilities operated by the state of New Jersey, and held an additional seventeen days of hearings.
Decision
An involuntarily committed patient who has not been found incompetent, barring an emergency, has a qualified right to refuse psychotropic medication, especially when forced treatment violates his
First Amendment rights to freedom of speech or to practice his religion, or his
Eighth Amendment rights to be free of
cruel and unusual punishment
Cruel and unusual punishment is a phrase in common law describing punishment that is considered unacceptable due to the suffering, pain, or humiliation it inflicts on the person subjected to the sanction. The precise definition varies by jurisdi ...
. New Jersey's administrative policies, which provide for a second psychiatric opinion in the case of refusing patients, must give adequate scope for the exercise of that right to satisfy constitutional requirements. Additionally,
due process
Due process of law is application by the state of all legal rules and principles pertaining to a case so all legal rights that are owed to a person are respected. Due process balances the power of law of the land and protects the individual p ...
must be followed in order to forcibly medicate an individual against his will. Judge Brotman's order that the least restrictive alternative concept applied to choice of medications was upheld upon appeal.
Significance
Before this case, although attention had been focused on involuntary commitment standards, it was assumed that once the patient was hospitalized, hospitals could administer psychoactive medication without consulting either the patient or the family. This was the first case in which the focus shifted from standards of commitment to standards of treatment once hospitalized. This was the first of a series of cases that increasingly acknowledged patient rights to refuse treatment and right to least restrictive treatment by way of a variety of First Amendment rights including freedom of religion and thought as well as the ultimate right to privacy, control over one's own body.
However, as this case illustrates, applying the least restrictive principles and working with a patient on medication choices brings up difficult empirical issues in ranking treatment options in accord with constitutional rights.
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See also
*''
O'Connor v. Donaldson''
*''
United States v. Binion''
*''
Washington v. Harper''
*''
Jackson v. Indiana''
*''
Perry v. Louisiana''
*''
Rogers v. Okin''
*''
Youngberg v. Romeo''
Footnotes
External links
* {{caselaw source
, case = ''Rennie v. Klein'', 462 F. Supp. 1131 (D.N.J. 1978)
, courtlistener =https://www.courtlistener.com/opinion/2142341/rennie-v-klein/
, googlescholar = https://scholar.google.com/scholar_case?case=4948996635246689882
, justia =https://law.justia.com/cases/federal/district-courts/FSupp/462/1131/2142341/
1978 in New Jersey
1978 in United States case law
Ethics in psychiatry
Medical controversies in the United States
United States civil commitment case law
United States District Court for the District of New Jersey cases
Winslow Township, New Jersey