Steele v. Hamilton County Community Mental Health Board (2000)

STEELE V. HAMILTON CTY. COMMUNITY MENTAL HEALTH BD.
Name
Institution
Abstract
For a long time, the rights of a patient remanded in a mental institution or an ordinary prison were ignored, and the state had the ability to enforce whatever treatment it saw fit. The ill treatment of the involuntarily incarcerated inmates led to numerous legal debates, especially with patients increasingly suing various state bodies that tried to treat them against their will. Furthermore, those who were under forced medication sought to challenge their treatment. In response, the courts were responsible for enforcing and interpreting various legal provisions in regards to the treatment of the involuntarily committed.
In this regard, the landmark case, Steele v Hamilton County contributed significantly in identifying the due process to be followed in the attempt to establish whether a patient posed any danger to the public. Furthermore, other legal issues that were addressed include the need for independent assessments of the patient and the need for patient privacy to be respected. This research explores the various legal issues that were raised and how the court responded to each of them.
Introduction
Over the years, numerous cases have explored “the right of a person who is involuntarily incarcerated” to reject treatment on various grounds. Also, numerous precedents have been set by either, the state courts of appeal or the Supreme Court of America, asserting the right of persons who are considered mentally unstable to determine whether they can be treated with antipsychotics (Merino, 2011).

Further complicating this issue is the need for medical practitioners to prioritize the health of inmates in regards to the Hippocratic Oath and other ethical regulations. In this regard, different rules have been set to determine the capacity of a patient in a psychiatric unit or an ordinary prison to be exempt from forced medication.
In the landmark case of Steele v Hamilton County Community Mental Health, several issues were raised. For instance, there were questions whether “the state had the right to override the right to privacy” in the light of its duty to uphold public welfare. Furthermore, various issues emerged in regards to the relevant authority to determine the need for involuntary treatment. Other important issues that were raised include the factors that determine whether a patient will be forcibly treated and whether less intrusive methods have proven ineffective. Finally, the ability or lack of it in regards to the patient’s ability to provide consent was another issue that was examined in regards to the state’s power to exercise parens patriae laws.
In response to the various legal matters that were identified, the court held that there was a need for stringent regulations to be undertaken to forcefully treat mentally unstable patients who were involuntarily incarcerated (Saks, 2002). For instance, a three-part test was established by the Court to ensure that before a patient was forcibly medicated, the state had accurately identified the need for it. First, the court stated the need for an examination into the reasons why the patient declined the medication. In this regard, “the court must determine under what circumstances, if any, will the patient yield to competing for state interests.” According to the court “The forcible injection of medication into a nonconsenting person’s body represents a substantial interference with that person’s liberty.” (No. 99-1771, 2000). Therefore, various reasons such as religious practices and phobia must be taken into consideration before treatment is accented. The court insisted since the effects of anti-psychotic on the human body are well documented, reasons for patient rejections must be well established first.
Part two of the necessary test includes “the determination whether the involuntarily incarcerated persons was a significant threat to their well-being and that of the public.” The state must fully establish whether the patient posed a risk to the public welfare that was due to their mental health state. The court referred to Ronnie v Klein to show that previously, hospital staff and prison officials have given antipsychotic medication to patients to prevent them from harming themselves or others (No. 99-1771, 2000). By application of its police powers to prevent harm to the public, medical officials have the right to determine immediately whether the patient poses a risk to themselves and others, and for the doctor or other relevant prison officials to subdue the patient with appropriate medication. However, this power is only applicable in the lack of alternative methods that are less intrusive and that the drugs used are medically suitable to the patient.
Furthermore, the court held that the state had the right to invoke parens patriae powers to forcefully medicate a patient, regardless of their opposition to the process. By citing the need to care for infirm patients, the state has the right to administer antipsychotic medication to mentally ill patients in the scenario that it was determined that the patient was unable to make informed decisions regarding their health. However, this is only applicable in instances where it has been established that the patient lacked the capacity to determine what was in their best interest, as identified in Addington v. Texas and that “The mere presence of psychosis, dementia, mental retardation, or some other form of mental illness or disability is insufficient in itself to constitute incompetence” since according to state laws, a mentally ill person still retained all their civil liberties (No. 99-1771, 2000).
The third requirement as held by the court was that in respect to due process as provided for by the Fourteenth Amendment, an independent “psychiatrist or a licensed clinical psychologist and a licensed physician must be appointed to examine the patient, to evaluate the recommended treatment” (No. 99-1771, 2000). Furthermore, the doctor is bound by various laws governing their profession, and they must carry out an independent assessment of the patient and recommend the least invasive form of treatment. Furthermore, the state has to take utmost care in caring for the patient’s right, by appointing an attorney if there are none and provision of a guardian ad litem to look after the patients best interests. Furthermore, the court must provide for additional hearings to determine the efficiency of the medication if granted (No. 99-1771, 2000).
The effect of this ruling, in the opinion of many legal and medical scholars, was mostly of a positive nature. For instance, Rozovsky noted that treatment facilities have previously medicated patients without regard for their privacy, consent or well-being. Furthermore, many other patients were grossly misdiagnosed without proper assessment and subjected to medication that has been noted to impact the patient in a manner of ways, some of which are lifelong (Rozovsky, 2015). In this regard, many treatment facilities had to change their operational procedure to avoid potential lawsuits in regards to the application of antipsychotic, mind altering drugs to pacify patients.
References
Merino, N. (2011). Medical ethics (1st Ed.). Detroit: Greenhaven Press.
No. 99-1771, O. (2000). “Steele v. Hamilton County Community Mental Health Board.” (1st ed., pp. 1-18). Ohio: Ohio Supreme Court.
Rozovsky, F. (2015). Consent to treatment (5th Ed.). Boston: Little, Brown.
Saks, E. R. (2002). “Refusing care: Forced treatment & the rights of the mentally ill.” Chicago: “University of Chicago Press.”