Pennhurst State School and Hospital v. Halderman explained

Litigants:	Pennhurst State School and Hospital v. Halderman
Arguedate:	February 22
Argueyear:	1983
Rearguedate:	October 3
Reargueyear:	1983
Decidedate:	January 23
Decideyear:	1984
Fullname:	Pennhurst State School and Hospital v. Halderman
Usvol:	465
Uspage:	89
Parallelcitations:	104 S. Ct. 900; 79 L. Ed. 2d 67
Docket:	81-2101
Oralargument:	https://www.oyez.org/cases/1980/79-1404
Oralreargument:	https://www.oyez.org/cases/1982/81-2101
Majority:	Powell
Joinmajority:	Burger, White, Rehnquist, O'Connor
Dissent:	Stevens
Joindissent:	Brennan, Marshall, Blackmun
Dissent2:	Brennan
Lawsapplied:	U.S. Const. amend. XI Developmentally Disabled Assistance and Bill of Rights Act of 1975

Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984), was a United States Supreme Court decision holding that the Eleventh Amendment prohibits a federal court from ordering state officials to obey state law.^[1]

Background

The lawsuit was a federal class action,^[2] asserting that those with developmental disabilities in the care of the state have a constitutional right to appropriate care and education.^[3] Terri Lee Halderman had been a resident of Pennhurst State School and Hospital, and following multiple episodes of abuse, she and her family filed suit in the federal district court. The suit started after Halderman had visited her parents at home and was found to have unexplained bruises. Although the case was not expected to reach the level it did, the courts later found that conditions at Pennhurst were unsanitary, inhumane and dangerous, violating the Fourteenth Amendment, and that Pennhurst used cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments, as well as the Pennsylvania Mental Health and Retardation Act of 1966 (MH/MR).^[4] The District Court ruled that certain of the patients' rights had been violated. The District Court decision was the first time that any federal court ruled that an institution must be closed based on a constitutional right to community services.^{[5] [6]}

Bibliography

Court documents

Law journal analyses

• Boyd . Penelope A. . 1981 . The Aftermath of the DD Act: Is there Life after Pennhurst? . University of Arkansas at Little Rock Law Journal . University of Arkansas at Little Rock, Bowen School of Law . 4 . 3 . 448–466.
• Brant . Jonathan . 1983 . Pennhurst, Romeo, and Rogers: The Burger Court and Mental Health Law Reform Litigation . The Journal of Legal Medicine . 4 . 3 . 323–348 . 10.1080/01947648309513387. 6605401 .
• Brant . Jonathan . 1983 . The Hostility of the Burger Court to Mental Health Law Reform Litigation . Bulletin of the American Academy of Psychiatry and the Law . 11 . 1 . 77–90. 6850110 .
• Chemerinsky . Erwin . Summer 1985 . State Sovereignty and Federal Court Power: The Eleventh Amendment after Pennhurst v. Halderman . Hastings Constitutional Law Quarterly . University of California, Hastings College of the Law . 12 . 4 . 643–668 . 2016-06-22 . https://web.archive.org/web/20151016222118/http://www.hastingsconlawquarterly.org/archives/V12/I4/Chemerinsky.pdf . 2015-10-16 . dead .
• Ferleger . David . Boyd . Penelope A. . April 1979 . Anti-Institutionalization: The Promise of the Pennhurst Case . Stanford Law Review . Stanford Law School . 31 . 4 . 717–752 . 10.2307/1228423 . 1228423. 10242374 .
• Ferleger . David . Scott . Patrice Maguire . 1983 . Rights and Dignity: Congress, the Supreme Court, and People with Disabilities after Pennhurst . Western New England Law Review . Western New England University School of Law . 5 . 3 . 327–361 . 11658602 .
• Smith . Peter J. . May 2001 . Penshurst, Chevron, and the Spending Power . Yale Law Journal . The Yale Law Journal Company, Inc. . 110 . 7 . 1,187–1,245. 10.2307/797527 . 797527 . 53607082 .

Journalism

• News: . 15 July 1984 . Pennsylvania Settles Key Suit on Facilities for the Retarded . New York Times . 1 November 2016.
• News: Levey . Noam N. . 25 February 2015 . The Conservative Ruling that Might Save Obamacare . Los Angeles Times . Los Angeles, Cal. . 20 June 2016.
• Web site: McIntyre . Adrianna . 3 March 2015 . Understanding 'Pennhurst': The Legal Doctrine that Could Save Obamacare . VOX . 20 June 2016.

Other sources

• Conroy . James W. . Bradley . Valerie . 1 March 1985 . The Pennhurst Longitudinal Study: A Report of Five Years Research and Analysis . Philadelphia, Penn. . Temple University Developmental Disabilities Center . 1 November 2016.

External links

• • Suffer The Little Children, a 1968 exposé on Pennhurst State School by NBC10 reporter Bill Baldini.

Notes and References

1. .
2. Halderman v. Pennhurst State School & Hospital. 446. F. Supp.. 1295. E.D. Pa.. 1978. http://law.justia.com/cases/federal/district-courts/FSupp/446/1295/2130357/. January 17, 2016.
3. U.S. District Court, e.D. . Pennsylvania. . Halderman v. Pennhurst State School and Hospital. 23 Dec 1977. . Federal Supplement . 1977 . 446 . 1295–329 . 11646079.
4. Web site: Pennsylvania Mental Health and Retardation Act of 1966. Temple University. Commonwealth of Pennsylvania. January 17, 2016. November 27, 2014. https://web.archive.org/web/20141127151353/http://www.temple.edu/thetrainingpartnership/resources/MHMRAct/MH-MRAct.pdf. dead.
5. Scott. P.M.. Ferleger. D.. Rights and dignity: Congress, the Supreme Court, and people with disabilities after Pennhurst. Western New England Law Review. 1983. 5. 3. 327–61. 11658602.
6. Anti-Institutionalization and the Supreme Court, 14 Rutgers L.Rev. 595 (1983).