Wyatt v. Stickney 


Patients working in the laundry at Bryce Hospital, Bryce Hospital Laundry Wyatt v. Stickney, filed in the federal United States District Court for the Middle District of Alabama on October 23, 1970, was a landmark ruling that established baseline care and treatment requirements for the institutionalized mentally disabled. The suit was filed on behalf of the patients at Bryce Hospital in Tuscaloosa, with 16-year-old Ricky Wyatt as the main plaintiff. Wyatt had been incarcerated for "delinquency" but had never received any other diagnosis of mental disability or condition. The defendants in the case were the Alabama Department of Mental Health (DMH) and its commissioner, Stonewall Stickney.

The suit initially was prompted by layoffs at Bryce Hospital, with attorneys alleging that insufficient staff at the hospital would prevent involuntarily committed mentally ill patients from receiving adequate treatment, a violation of their civil rights under the Fourteenth Amendment of the U.S. Constitution. Federal District Court judge Frank M. Johnson Jr. ruled in favor of the plaintiffs, concluding from evidence submitted during litigation that standards for adequate treatment did not exist. Johnson, assisted by Stickney (whom Johnson considered a progressive administrator and a party to the suit only as a matter of form), wrote two sets of detailed constitutionally mandated minimum standards for adequate treatment, one for the mentally ill and another for the mentally retarded. The DMH appealed the case to no avail. In 1975, Johnson placed the DMH under court rule, where it remained until 2003, for its inability to comply with the minimum standards.

The origins of the case lie in Act 881, passed by the state legislature in 1965 at the urging of the Medical Association of the State of Alabama. The law created the Alabama Mental Health Board, which in turn created an office of commissioner to oversee the DMH and its three residential hospitals. The three facilities—Partlow State School and Hospital in Tuscaloosa for the mentally retarded, Searcy Hospital in Mount Vernon, and Bryce Hospital in Tuscaloosa for the mentally ill—housed more than 10,000 involuntarily committed patients.

In the summer of 1970, the state legislature reduced the state’s appropriation to the DMH, forcing Commissioner Stickney to cut the DMH budget by one percent and to lay off 99 employees at Bryce Hospital. On October 23, 1970, attorneys George Dean and Jack Drake filed a class action suit against the DMH, naming two classes as plaintiffs: one designating Ricky Wyatt and the Bryce patients and the other consisting of the dismissed employees. Judge Johnson stated that DMH had the legal right to discharge its employees when faced with budget shortfalls and dismissed the latter case. Johnson was concerned, however, about patients' rights to adequate treatment and heard the former case. With less staffing at Bryce, he reasoned, existing and future patients would receive inadequate treatment and would suffer incarceration without the benefit of due process of law.

On January 4, 1971, George Dean amended the original complaint requesting that DMH operate Bryce in accordance with constitutionally guaranteed rights to due process and adequate treatment. Accompanying this request, Dean provided evidence that patients received inadequate treatment and that the hospital was understaffed and underfunded. Of its 5,000 patients, 1,600 were geriatric patients and more than 1,000 were mentally retarded, both groups receiving custodial care but no psychiatric treatment. In terms of staffing, the hospital employed 17 physicians, 12 psychologists with varying academic qualifications and levels of experience, 21 registered nurses, 13 social service workers, 12 patient-activity workers, and approximately 900 psychiatric aides to treat the 5,000 patients. The employees whose duties involved direct patient care in the therapeutic programs, however, included only one clinical psychologist, three medical doctors with some psychiatric training, and two social workers. Alabama’s daily expenditure per patient was $6.00, with a daily food allowance of less than $0.50, compared to the national average of $15.00 a day.

On March 12, 1971, the District Court ruled on the motion of plaintiffs for preliminary injunction. Johnson stated that committed patients have a constitutional right to receive individual treatment designed to provide them a realistic opportunity to be cured or to improve their mental condition. Depriving citizens of their liberty upon the theory that the confinement is humane and therapeutic and then failing to provide adequate treatment violates the fundamentals of due process, he reasoned. After his ruling, Johnson became very active in directing the case. He allowed the patients at Searcy Hospital and Partlow State School and Hospital to join the suit as additional plaintiffs. He invited several groups to testify or otherwise participate in the case as amicus curiae, or friends of the court, including the American Psychological Association, the American Ortho-Psychiatric Association, the American Civil Liberties Union, the American Association on Mental Retardation, and the U.S. Departments of Justice and U.S. Department of Health, Education and Welfare. The American Psychiatric Association, the National Association for Retarded Citizens, and the National Association for Mental Health joined later. Johnson also ordered Stickney, the Alabama Mental Health Board, and the state to prepare and implement an acceptable plan providing adequate treatment at the three hospitals; the plan never came to fruition, however, owing to lack of funds, staff, and time.

The court heard testimony from various organizations, committees, and individuals concerning both the appalling conditions at the three hospitals and recommendations to improve treatment. Johnson in response composed a set of minimum standards outlining adequate treatment using Stickney’s "Philosophy and Goals of a Mental Health Department," the guidelines that Stickney and Deputy Superintendent Dr. James Folsom had previously proposed, and recommendations from the amicus curiae. On April 13, 1972, Judge Johnson issued his historic order containing the minimal constitutional treatment standards for the mentally ill and the mentally retarded. These standards, later referred to as the Wyatt Standards, rested on three principles: individualized treatment plans, qualified staff in numbers sufficient to administer adequate treatment, and humane psychological and least restrictive environments.

In May 1972, Gov. George C. Wallace Jr. and the Alabama Mental Health Board appealed Johnson’s ruling, but on November 8, 1974, the U.S. Circuit Court of Appeals in New Orleans ruled in favor of Johnson’s decision, sealing the standards as national guidelines for both the medical and legal professionals. DMH was unable to comply, however, because it could neither attract enough professionals to meet the new patient-to-physician ratio nor allocate sufficient funds to upgrade the hospital facilities and the patients' treatment procedures. As a result, the court released more than half of the hospitals' patients by 1975. Compounding DMH problems was the fact that many hospital employees did not adhere to the Wyatt Standards when treating the patients. In June 1977, based on information received from in-house human rights committees and journalist Paul Davis concerning physical abuse to the patients by the employees, Johnson placed the DMH under court rule and provided the Partlow facility with a federal court officer to monitor its compliance with the standards and to report any discrepancies to the court.

On January 15, 1980, the Middle District court placed the newly named Department of Mental Health and Mental Retardation (DMH/MR) in receivership under Gov. Forrest "Fob" James. Although DMH/MR failed to comply with the standards on James's watch, the agency did make some progress. In the following years, Alabama built smaller, more modern and code-compliant community centers to reduce the overcrowding at the three hospitals.

In 1986, the DMH/MR entered into a new consent decree with the plaintiffs that required all facilities to achieve accreditation from the Joint Commission on the Accreditation of Healthcare Organizations and comply with the healthcare facility requirements of Title XIX, the Social Security Act. The decree focused on the guidelines of the Wyatt Standards, calling for the development of quality care, an internal advocacy system, and the placement of patients in community centers. The decree also replaced court monitors with the Wyatt Consultant Committee, consisting of a director of Internal Advocacy and four outside experts to advise the DMH/MR on ways to achieve compliance.

Although the DMH/MR had worked diligently with the plaintiffs to secure compliance, District Court judge Myron Thompson ruled in 1995 that the state still lacked compliance with approximately 30 percent of the Wyatt Standards. Nevertheless, Thompson did release several mental health centers from supervision. Over the next three years, the DMH/MR made significant progress in developing community services, a supporting infrastructure, and an internal advocacy program. In 1999, the court dissolved the 1986 consent decree and approved a new settlement agreement, allotting the DMH/MR three years to implement the agreement’s specific requirements.

On October 1, 2000, Commissioner Kathy Sawyer established 12 work groups to develop compliance plans. Sawyer also incorporated the Wyatt Standards into the DMH/MR’s policies and procedures manual, requiring all facilities to implement and adhere to these policies. A court-ordered evaluation concluded that the state had significantly transformed the attitude and performance of the DMH/MR. On December 5, 2003, Judge Thompson held a fairness hearing to consider whether the state had complied with the 1999 settlement agreement. Satisfied with DMH/MR’s performance of ensuring the constitutional right of civilly committed mental patients to receive adequate treatment, Thompson terminated the lawsuit. In attendance at the hearing was 49-year-old Ricky Wyatt. Spanning more than 33 years and costing the state more than $15 million in litigation fees, the Wyatt case came to a close.

Additional Resources 

Jones, L. Ralph and Richard R. Parlour, ed. Wyatt v. Stickney: Retrospect and Prospect. New York: Grune & Stratton, 1981.

Whitehead, Jeanne Anne. "The Making of a Constitutional Right: Wyatt v. Stickney, An Experiment in Social Reform." Master's thesis, University of North Carolina, 1981.

Deborah J. Belcher
Auburn University


Published August 6, 2009
Last updated November 15, 2012