Free Essay: Wyatt v. Stickney Case

Published: 2022-11-18
Free Essay: Wyatt v. Stickney Case
Type of paper:  Case study
Categories:  Court system Mental health Civil rights
Pages: 5
Wordcount: 1188 words
10 min read

A federal court made a landmark ruling that patients involuntarily admitted in institutions of the state given the right treatment offering them the opportunity of returning into the society. The ruling was done at a court in Alabama and focused on patients having disabilities including mental disorders. The case lasted more than thirty years to come up with a favorable decision, hence considered the most extended lawsuit is running about mental illness. The case incurred considerable costs to find its way through the federal court system, estimated at 15 million dollars.

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The landmark decision by the case resulted in reforming of the United States mental health institutions. For instance, it led to the creation of the least standards of care observed when rehabilitating the patients who have a mental illness (Disability Justice, 2019).

Facts and Major Issues

The Wyatt v. Stickney litigation, initiated in the year 1970 by Alabama's decision to lower the cigarette tax. That decision sparked conflict among the interested parties as the proceeds from cigarette tax were channeled to facilitate delivery of mental health services. Hence, the reduction in tax interrupted proper delivery of health care services, for instance, elimination of approximately 100 staff personnel from the Bryce Hospital. Among the 100 staff members eliminate, 20 were psychology professionals. That prompted the excluded staff members to file a lawsuit on October 23, 1970, in the U.S. District Court to facilitate their reinstatement to their former positions. One of the reasons cited in the staff members petition includes, their elimination will make patients suffer more as there is the reduction of medical caregivers.

To strengthen their petition, the group of eliminated staff members incorporated one of the patients to the case by the name Ricky Wyatt. Wyatt position determined to be that of a plaintiff. Although Wyatt, not a mental illness patient, was placed at the mental institution to rehabilitate his delinquent behavior. Soon enough, the number of the plaintiffs increased with the incorporation of patients from neighboring hospitals. For instance, Searcy Hospital and Alabama state facility. The increase in a number of the plaintiffs shifted the focus from advocating for the rights of the medical staff members to the rights of the residents.

Following the events regarding the elimination of staff members from state institutions, Alabama State was ranked number 50 in the United States for proper delivery of medical services. The conditions at the public health institution reduced to what the residents termed as "concentration camp," due to the old conditions present. Treatment and nursing operations were awful to facilitate proper recovery of patients suffering from mental illnesses or any other disabilities. For instance, The Bryce Hospital understaffed with only three medical doctors and one clinical psychologist having limited experience in therapeutic care (Disability Justice, 2019).

Fundamental Principles

The United States District Court Judge considered some fundamental principles which formed the basis of ruling the case. The Judge determined the patients have the constitutional right to receive specialized treatment, with the goal of ensuring either of the patients obtain a realistic chance of getting incorporated back into the society. Moreover, the patients were committed involuntarily without constitutional protection and noncriminal procedures, essential to defendants during criminal proceedings. Another fundamental principle is that effective and adequate treatment is a constitutional right because its absence makes the healthcare institution transformed into a prison. Moreover, deprivation of any citizen's liberty and freedom of movement citing therapeutic reasons them failing to deliver the conventional treatment is tantamount to violating the due process.


The ruling of the case based on three fundamental principles that were violated by the defendants of the case: i) A human physical and psychological environment; ii) Sufficient and qualified staff to deliver quality treatment, and iii) Personalized treatment plans. In his verdict, the judge concluded deficiency at the Bryce Hospital with regards to the fundamental criteria fore-mentioned. On April 13, 1972, the court issued two opinions, one focused on Search and Bryce Hospitals, whereas the other directed on Partlow State School and Hospital. Regarding Partlow State School, the judge accorded the same residents to the residents as those granted to the patients admitted to state facilities involuntarily. The ruling was in the context of the right to proper care for individuals confined at mental institutions civilly, whereby no discrete distinction achieved between mentally disabled and mentally ill individuals given that the only justification did constitutionally for civilly undertaking a mental retardate is habilitation. Therefore, based on ineluctably, such an individual is seized of a constitutional right to habilitation, considered inviolable.

The Judge ordered the formation of a committee tasked with overseeing the implementation of the "Wyatt Standards." The Wyatt Standards are considered to be a set of constitutional standards at a bare minimum which facilitates effective treatment of people suffering from developmental disabilities and mental illness. The Partlow School set standards determined residence at the institution considered least restrictive habilitation and personalized to an individual.

The Implication

The Wyatt Standards affirmed by Judge Johnson became the conventional standards nationally for the treatment and care for patients suffering from developmental illness and mental illness. The set rules were agreed upon by the United States Court of Appeals, and the orders leading to the Wyatt Standards implementation on November 8, 1974. For the next thirty years, the case Wyatt v. Stickney was referred to regularly by other federal courts in the United States during disputes concerning the implementation of the set standards by Judge Johnson. The increase in an appearance at federal court dockets of the Wyatt v. Stickney case led to the creation of multiple consent decrees and monitored appointed by the court. In the time, there was the growth of community alternatives, consequently, the decline in the number of people living in Alabama state institutions.

The Wyatt v. Stickney case had a significant effect on the development of United States law concerning treatment and care of patients suffering from developmental disabilities and mental illnesses. For instance, incorporation of the Wyatt Standards in federal regulations and state mental health codes revolutionized and the delivery of treatment to the patients. Furthermore, the idea of facilitating treatment in the lowest restrictive setting reflected in the Act of Americans with Disabilities. The United States Supreme Court agreed that in Olmstead. Moreover, the role developed by Judge Johnson of "litigating amicus" for the Department of Justice is currently taking the form of an institution in the Civil Rights of Institutionalized Persons Act (CRIPA) (Barczyk & Davis, 2009).


The Wyatt v. Stickney case established the right to sufficient treatment of patients. The major issues in the case include hardships in achieving balance between state and federal power structures, and the challenge of having to offer treatment and care without adequate resources. The case led to nationwide system for Protection and Advocacy considered a direct benefit of the Human Right Committee established by Judge Johnson during his ruling. The litigation provided a new perspective in habilitating individuals in state institutions.


Barczyk, A., & Davis, K. (2009). Analysis of the Civil Rights of Institutionalized Persons Act (CRIPA) of 1980: The Current Avenue for Protecting Individuals in Institutions. Journal Of Policy Practice, 8(3), 188-203. doi: 10.1080/15588740902827806

Disability Justice. (2019). Wyatt v. Stickney | Disability Justice. Retrieved from

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