3 Pennsylvania Court Cases That Changed The World

Pennhurst was the battleground for several landmark decisions that improved conditions for the developmentally disabled around the world.

  1. Halderman v. Pennhurst
  2. Right To Education
  3. Youngberg v Romeo

Halderman v. Pennhurst State School and Hospital

The allegations of abuse at Pennhurst led to the first lawsuit of its kind in the United States, a federal class action, Halderman v. Pennhurst State School & Hospital, which asserted that the developmentally disabled in the care of the state have a constitutional right to appropriate care and education. Terri Lee Halderman had been a resident of Pennhurst, and following multiple episodes of abuse, she and her family filed suit in the federal district court. The suit started after Terri 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). 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.

Click here to see the actual court filings

Right To Education

In 1971, the seminal lawsuit Pennsylvania Association for Retarded Children (PARC) v. Commonwealth of Pennsylvania, was the first right-to-education suit in the country to overturn that Pennsylvania law and secure a quality education for all children. The case quickly settled before the U.S. District Court for the Eastern District of Pa., resulting in a consent decree in which the state agreed to provide a free public education for children with mental retardation. That decree and many of the procedural protections in it became the basis for the Education for All Handicapped Children Act (PL 94-142) enacted in 1975. The next year the Law Center filed PARC II to enforce the Act against the School District of Philadelphia.

Click here to see the actual court filings

Youngberg v Romeo (1982)

Respondent, who is mentally retarded, was involuntarily committed to a Pennsylvania state institution. Subsequently, after becoming concerned about injuries which respondent had suffered at the institution, his mother filed an action as his next friend in Federal District Court for damages under 42 U.S.C. § 1983 against petitioner institution officials. She claimed that respondent had constitutional rights to safe conditions of confinement, freedom from bodily restraint, and training or "habilitation" and that petitioners knew, or should have known, about his injuries but failed to take appropriate preventive procedures, thus violating his rights under the Eighth and Fourteenth Amendments. In the ensuing jury trial, the District Court instructed the jury on the assumption that the Eighth Amendment was the proper standard of liability, and a verdict was returned for petitioners, on which judgment was entered. The Court of Appeals reversed and remanded for a new trial, holding that the Fourteenth, rather than the Eighth, Amendment provided the proper constitutional basis for the asserted rights. Held : Respondent has constitutionally protected liberty interests under the Due Process Clause of the Fourteenth Amendment to reasonably safe conditions of confinement, freedom from unreasonable bodily restraints, and such minimally adequate training as reasonably may be required by these interests. Whether respondent's constitutional rights have been violated must be determined by balancing these liberty interests against the relevant state interests. The proper standard for determining whether the State has adequately protected such rights is whether professional judgment in fact was exercised. And in determining what is "reasonable," courts must show deference to the judgment exercised by a qualified professional, whose decision is presumptively valid.

Click here to see the actual court filings