1. Wyatt v. Stickney:
Testing the 8 th
Amendment & the Right
to Treatment
Sherwood Best, Ph.D.
Professor, CSULA
EDSP 501
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2. Wyatt
v.
Stickney
325 F. Supp 781
(Middle District of Alabama 1971)
344 F. Supp 373
(Middle District of Alabama, 1972)
Filed October 23, 1970
Decided April 13, 1972 2

3. Terminology
Habilitation– Treatment provision for
individuals whose disability is
congenital. To make capable…
Rehabilitation – Treatment provision
for individuals who experience
disability after injury or illness; to
restore to former capacity…
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4. Background
After a budget cut reduced state finances in
Alabama, a staff reduction was implemented
at the Bryce State Hospital in Tuscaloosa
for persons with mental illness. As a
result of that cut and subsequent staff
reduction, hospital residents experienced a
sharp decline in habilitative services.
Residents who exhibited non-compliant and
aggressive behavior began to receive
increased amounts of medication and
even physical restraint in order to “protect”
themselves and other residents. 4

5. Background… of
A class action lawsuit was brought on behalf
Ricky Wyatt by his aunt and guardian against the
State of Alabama and Stonewall B. Stickney,
Commissioner of Mental Health and the State of
Alabama Mental Health Officer in which it was
alleged that the residents in the institutions were
being subjected to cruel & unusual
punishment – a situation prohibited by the 8th
Amendment.
In 1971, the class was enlarged to include patients
with mental illness & mental retardation in other
state institutions in Alabama.
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6. Background
 Additional defendants in the case:
 Agnes Baggett, Treasurer - State of Alabama
 Roy Sanders, Comptroller - State of Alabama
 Ruben King, Commissioner of Pensions &
Security
 George Wallace, Chairmen of Alabama State
Board of Pensions & Security
 James Bailey, as a representative member of
the Alabama State Board of Pensions & Security
 Stanley Frazer, Director of Alabama State
Personnel Board
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7. Issues
 Were the 8th Amendment rights of
residents at State Hospital being
violated?
 Were unavailability of funds, staff,
& facilities adequate justification by
the defendants to default in provision
of suitable treatment for the
mentally ill?
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8. Applicable Law
8th Amendment
“Excessive bail shall not be
required, nor excessive fines
imposed, nor cruel and unusual
punishment inflicted.”
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9. Arguments
 Plaintiffs argued that the residents at
State Hospital had committed no crime, yet
were living in an institution where they
were deprived of habilitation. Therefore,
their “incarceration” = penal confinement.
 Defendants argued that budget cutbacks
necessitated measures to protect the
residents from themselves and others, even
if that protection involved chemical and
physical restraint.
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10. Holding
 The 8th Amendment rights of individuals residing
in the State Hospital had been violated. They had
committed no crime, and were therefore entitled
to all appropriate and necessary habilitation
services.
 Committed patients “unquestionably have a
constitutional right to receive such individual
treatment as will give each of them a realistic
opportunity to be cured or to improve his
or her mental condition.”
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11. Dicta
 Court found the defendants’ treatment
program deficient in 3 areas in that it failed
to provide:
 Humane psychological/physical environment
 Qualified staff in numbers sufficient to
administer adequate treatment
 Individualized treatment plans
 Additional considerations included:
 Nontherapeutic work assignments
 Absence of any semblance of privacy
 Dangerous resident overcrowding & emergency
hazards
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12. Dicta: Other Rights
 Visitation & telephone communications as patients
at other public hospitals
 Unrestricted right to send sealed mail
 Free from unnecessary/excessive medication
 Free from unnecessary restraint & isolation
 Not be subjected to experimental research without
express & informed consent
 Not to be subjected to lobotomy, electro-convulsive
treatment, adversive reinforcement conditioning
without express & informed consent
 Suitable opportunities for interaction with members
of the opposite sex
 Worship
 Physical exercise & regular time outdoors
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13. Court’s Orders
 The State of Alabama was ordered to restore
funding to State Hospital and reinstate staff to
appropriate levels to ensure habilitation.
 Mental Health Board of Alabama was directed to
sell or encumber land holdings to raise funds to
implement toe Court’s orders.
 Emergency procedures were implemented to
hire physicians to examine existing resident
drug programs.
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14. Court’s Orders
 Defendant’s would be allowed 6 months in
which to raise the level of care at Bryce
Hospital to a required minimum.
 Defendants were ordered to file reports
defining the hospital’s mission and function,
specifying the standards required to furnish
treatment to the residents, and detailing the
hospital’s progress toward implementation
of these standards.
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15. Implications for Special
Education Policy
 Idea of right to treatment &
individualized treatment plans evolved
from the Wyatt case.
 A spotlight on state institutions for persons
with mental illness and/or retardation led
to public recognition of substandard care in
many residential institutions.
 Deinstitutionalization of state facilities & re-
location of residents to community-based
facilities (and into public schools).
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