Community Treatment in Integrated Settings
Two court decisions stand out in their support of community care for people with mental illness. A class action lawsuit brought by District of Columbia patients at St. Elizabeth’s Hospital (Dixon v. Weinberger; 405 F. Supp. 974; U.S. District Court, District of Columbia, 1975) asserted that the 1964 Hospitalization of the Mentally Ill Act granted the right to care in community-based alternative settings for those unnecessarily confined to institutional care. The court ruled that treatment in community-based alternatives should be made available for those who do not meet criteria for mandatory hospitalization. Years later, in Olmstead v. L.C. (527 U.S. 581; 1999), the United States Supreme Court held that under the Americans with Disabilities Act, people with mental disabilities have the right to live and receive services in the most integrated settings appropriate to their needs.
The Right to Quality of Care
Finally, the decision in Wyatt v. Stickney (325 F. Supp 781 M.D. Alabama, 1971) is important because it helped to accelerate the emptying of state mental institutions. Wyatt v. Stickney was an action brought by the Department of Psychology at Alabama’s Bryce State Hospital to reverse job loss for over 100 employees, including professional staff, that occurred following a state budget deficit. The action alleged that the layoffs impaired needed treatment of patients. To emphasize the point, Ricky Wyatt, a patient and relative of a laid-off staff member, was included as a plaintiff. Federal district judge Frank M. Johnson dismissed the aspect of the lawsuit brought by hospital staff, contending that the state had the right to lay off employees. However, in addressing the portion of the action focused on patient grievances, the judge ruled that patients “unquestionably have a constitutional right to receive such individual treatment as will give each of them a realistic opportunity to be cured or to improve his or her mental condition” (http://forensicpsychiatry.standford.edu/Files/Wyattv.Stickney. htm) (Birnbaum, 1960). In his decision, Judge Johnson defined treatment adequacy in terms of staff-to-patient ratios, optimal staffing patterns, the preparation of treatment plans, the functioning of the physical plant, and other patient-care details such as frequency of showering, change of bed linens, and so forth. The inability of the state of Alabama to adhere to the standards set forth in the Wyatt decision and the high cost of transforming the grossly inadequate conditions in state mental hospitals compelled the state to rapidly discharge patients to the community. Similar court actions in other states produced the same result, accelerating the emptying of state mental institutions.