Youngberg v. Romeo Ex Rel. Romeo

Lawful commitment does not strip a person of all substantive liberty interests. The State conceded its obligation to provide essentials such as food, shelter, clothing, and medical care, and the Court held that personal security is likewise a historic liberty interest protected by the Due Process Clause.

The Court reasoned that even convicted prisoners retain constitutional protection against dangerously unsafe confinement. A person who has been civilly committed, and therefore may not be punished at all, must at least retain a constitutional right to reasonable safety.

The right is not a guarantee against every possible injury. Institutional officials must reconcile a resident's interest in safety with other legitimate interests, including the resident's own interest in having some freedom of movement.

Freedom from bodily restraint lies at the core of liberty protected by the Due Process Clause. That interest survives even criminal conviction and imprisonment, so it also survives civil commitment.

The right is qualified rather than absolute. A state institution may restrain a resident when professional judgment determines that restraint is necessary to protect the resident or others, or to provide needed training.

Because safety and liberty can conflict, constitutional analysis does not ask merely whether restraint occurred. It asks whether the restraint was reasonable in light of the resident's liberty interests and the State's legitimate institutional responsibilities.

As a general rule, a State has no constitutional obligation to furnish affirmative social services. But when the State institutionalizes a person who is wholly dependent upon it, the State assumes duties of care that may include training necessary to prevent unconstitutional losses of liberty.

The record showed that Romeo principally sought self-care and behavioral training to reduce aggression, injuries, and the need for physical restraint. Because training could protect his safety and permit greater freedom of movement, the Court held that minimally adequate training related to those interests may be constitutionally required.

The Court deliberately left open whether an involuntarily committed person has a general constitutional entitlement to training unrelated to safety or freedom from restraint. Romeo did not clearly present that broader claim on the record before the Court.

The Court rejected both the District Court's Eighth Amendment deliberate-indifference instruction and the Third Circuit majority's demanding compelling- or substantial-necessity tests. Those standards did not properly account for the distinctive due process rights of civilly committed persons or for the operational realities of state institutions.

Civilly committed residents are entitled to more considerate conditions than convicted prisoners, because they are not being punished. Yet federal courts should not substitute their own views, or those of juries, for the choices of qualified institutional professionals among professionally acceptable alternatives.

A qualified professional is someone competent by education, training, or experience to make the decision at issue. Long-term treatment decisions ordinarily require trained medical, nursing, psychological, therapeutic, or habilitation professionals, while day-to-day decisions may be made by supervised staff.

The professional-judgment standard creates a presumption of validity for professional decisions. Expert evidence remains relevant because it may show that an official's decision substantially departed from accepted standards, but mere disagreement over which acceptable course should have been chosen does not establish a constitutional violation.

Applying this framework, the Court held that the jury instructions were erroneous because they rested on Eighth Amendment concepts. It therefore vacated the Third Circuit's judgment and remanded for proceedings under the professional-judgment standard.