Youngberg v. Romeo, 457 U.S. 307 (1982)

Court and Agency Decisions and Orders (including case law)

In this landmark decision, the Supreme Court held that individuals committed to state institutions have a substantive right under the 14th amendment to be free from excessive bodily restraint, the right to personal security and protection, and the right to adequate treatment. The Court upheld the Court of Appeals finding that the 14th amendment, not the 8th amendment, should be the basis to determine the appropriate standard of care. This case is significant because it established that individuals held in confinement are constitutionally guaranteed the right to safe conditions.

The complaint was filed on behalf of Romeo, a severely developmentally disabled patient, who continuously suffered injuries while a patient at a state institution. After his mother's original complaint, Romeo was transferred to the hospital where he was physically restrained multiple times each day. Her second amended complaint alleged that Romeo was not receiving appropriate treatment for his mental retardation in addition to the claims of her original complaint.

The Supreme Court upheld the ruling of the Third Circuit of Appeals that when a person is put under the care of the state, it is the state's duty to provide safe living conditions. Additionally, the state has a duty to provide training for individuals held in its custody to make certain that his/her own safety is ensured and prevent the need for bodily restraints. Any infringements on a patient's rights to these protections must be based on professional judgment and clear standards.

The reasoning used in Youngberg relies on the state's obligation to ensure the safety of individuals in their custody. This obligation extends to youth in their custody who rely on the state to act as their guardian. Applying this ruling, the juvenile justice system must offer youth protection and provide them with the appropriate treatment and medical care.  Youngberg remains good law, and its application to youth in state custody is discussed extensively in Juvenile Injustice: The Unfulfilled Rights of Youth in State Custody to Comprehensive Sexual Health Care.

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