approving of the administration of anti-psychotic drugs to involuntary patients where “such an action is deemed necessary to prevent the patient from endangering himself or others ” (emphasis added)
How later courts described this case
- approving of the administration of anti-psychotic drugs to involuntary patients where “such an action is deemed necessary to prevent the patient from endangering himself or others ” (emphasis added)
- reconsideration of Rennie in light of Youngberg led court to reject "least intrusive means" test.
- “Unlike the temporary and predictable effects of bodily restraints, the permanent side effects of antipsychotic drugs induce conditions that cannot be corrected simply by cessation of the regimen. The permanency of these effects is analogous to that resulting from such radical surgical procedures as a pre-frontal lobotomy.”
- anti-psychotic drugs may be constitutionally administered to an involuntarily committed mentally ill patient, whenever, in the exercise of professional judgment, such an action is deemed necessary to prevent the patient from endangering himself or others
Written by the judges who cited it.
The opinion
GIBBONS, Circuit Judge, dissenting:
I join in Judge Weis’ opinion setting forth the legal standards applicable by virtue of the fourteenth amendment to the involuntary imposition of medical treatment by persons acting under color of state law. Unlike Judge Weis, however, I dissent from the judgment insofar as it modifies the preliminary injunction which was entered by the trial court. The reasons for my dissent are set out in the opinion which I filed when the case was first considered by the full court. See Rennie v. Klein, 653 F.2d 836, 865-70 (3d Cir.1981) (in banc), Gibbons, J., dissenting. They need not be repeated. I would affirm the district court in all respects.