Rennie v. Klein

Overview
Rennie v. Klein was a case heard in the Federal District Court of New Jersey in 1978 to decide whether an involuntarily committed mental patient has a constitutional right to refuse psychiatric medication. It was the first case to establish that such a patient has the right to refuse medication.

Circumstances
John Rennie. age 38, was a former pilor and flight instructor who was a patient at Ancora State Hospital in New Jersey. His case was brought in December 1977. Rennie psychiatric history indicates that he did not show signs of mental illness until he was 31. His first hospitalization occurred in 1973 and subsequently he became a revolving door patient, 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-depression psychosis. Rennie had persistent religious delusions (he thought he was Christ) and suicidal ideation. 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, various psychiatric medications had been tried without clear success. Rennie sued in federal district court to enjoin the hospital from administering psychotropic 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, and 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. The long acting drug, they believed, would be the easiest drug on which to maintain him after release. Following initiation of the prolixin regime, Rennie's condition did improved 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, 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. New Jersey's administrative policies, which provide for a second psychiatric opinion in the case of refusing patients, give adequate scope for the exercise of that right to satisfy constitutional requirements. Additionally, due proces 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 standard, it was assumed that once the patient was hospitalized, hospitals could administer psychoactive medication without consulting either patient or family. This was the first case that the focus shifted from standard of commitment to standards of treatment once hospitalized. This was the first of a series of cases that acknowledging 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 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.