Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984), was a United States Supreme Court decision holding that the Eleventh Amendment prohibits a federal court from ordering state officials to obey state law.[1]
Background
The lawsuit was a federal class action,[2] asserting that those with developmental disabilities in the care of the state have a constitutional right to appropriate care and education.[3] Terri Lee Halderman had been a resident of Pennhurst State School and Hospital, and following multiple episodes of abuse, she and her family filed suit in the federal district court. The suit started after Halderman had visited her parents at home and was found to have unexplained bruises. Although the case was not expected to reach the level it did, the courts later found that conditions at Pennhurst were unsanitary, inhumane and dangerous, violating the Fourteenth Amendment, and that Pennhurst used cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments, as well as the Pennsylvania Mental Health and Retardation Act of 1966 (MH/MR).[4] The District Court ruled that certain of the patients' rights had been violated. The District Court decision was the first time that any federal court ruled that an institution must be closed based on a constitutional right to community services.[5][6]
Panel discussion, "The Disability Rights Movement: From Pennhurst Until Today", U.S. Capitol Visitor Center, Washington, D.C., 27 June 2016. Left to right: James W. Conroy, principal investigator on the Pennhurst Longitudinal Study and co-president of the Pennhurst Memorial and Preservation Alliance; Nancy Thaler, Deputy Secretary, Pennsylvania Department of Human Services; Peter Berns, chief executive officer, the Arc of the United States; Jean Searle, member of the Pennhurst class and co-president of the Pennhurst Memorial and Preservation Alliance; Thomas Gilhool, Public Interest Law Center of Philadelphia and lead plaintiff's attorney in Penshurst v. Halderman; Janet Albert-Herman, a board member of the Arc of Pennsylvania and Treasurer of the Pennhurst Memorial and Preservation Alliance.
References
^Pennhurst State School and Hospital v. Halderman, 465U.S.89 (1984).
^Halderman v. Pennhurst State School & Hospital, 446 F. Supp. 1295 (E.D. Pa. 1978).
^U.S. District Court, e.D., Pennsylvania. (1977). "Halderman v. Pennhurst State School and Hospital. 23 Dec 1977". Federal Supplement. 446: 1295–329. PMID11646079.
^Scott, P.M.; Ferleger, D. (1983). "Rights and dignity: Congress, the Supreme Court, and people with disabilities after Pennhurst". Western New England Law Review. 5 (3): 327–61. PMID11658602.
^Anti-Institutionalization and the Supreme Court, 14 Rutgers L.Rev. 595 (1983).
Bibliography
Court documents
Law journal analyses
Boyd, Penelope A. (1981). "The Aftermath of the DD Act: Is there Life after Pennhurst?". University of Arkansas at Little Rock Law Journal. 4 (3). University of Arkansas at Little Rock, Bowen School of Law: 448–466.
Brant, Jonathan (1983). "Pennhurst, Romeo, and Rogers: The Burger Court and Mental Health Law Reform Litigation". The Journal of Legal Medicine. 4 (3): 323–348. doi:10.1080/01947648309513387. PMID6605401.
Brant, Jonathan (1983). "The Hostility of the Burger Court to Mental Health Law Reform Litigation". Bulletin of the American Academy of Psychiatry and the Law. 11 (1): 77–90. PMID6850110.
Ferleger, David; Boyd, Penelope A. (April 1979). "Anti-Institutionalization: The Promise of the Pennhurst Case". Stanford Law Review. 31 (4). Stanford Law School: 717–752. doi:10.2307/1228423. JSTOR1228423. PMID10242374.
