Rennie V. Klein - Circumstances

Circumstances

John Rennie, age 38, was a former pilot and flight instructor who was a patient at Ancora State Hospital in New Jersey. His case was brought in December 1977. Rennie's psychiatric history indicates that he did not show signs of mental illness until he was 31. He was first hospitalized in 1973, and subsequently he was discharged and re-admitted many times, primarily, as trial judge Stanley Brotman noted, because of "his failure to continue taking medications after he has left the hospital's custody." He had been given various diagnoses over time including paranoid schizophrenia and manic-depressive psychosis. Rennie had persistent religious delusions (he thought he was Christ) and suicidal ideation. His eighth hospitalization was initiated after he threatened to kill President Ford. On subsequent hospitalizations he became increasingly abusive and assaultive.

In December 1977, during his twelfth hospitalization that began on August 10, 1976, doctors had unsuccessfully tried various psychiatric medications. Rennie sued in federal district court to prevent the hospital from administering psychotropic medications to him without a clear emergency. His counsel was the Office of the Public Advocate. As Judge Brotman describes in his decision, the precipitating factors occurred earlier in the month when Rennie had become homicidal. Hospital staff felt his condition was deteriorating; to prevent Rennie from harming other patients, staff, and himself, the treatment team administered prolixin decanoate, an injectable long-acting drug, because of his history of failing to take medication once released. They believed the drug would be the easiest drug on which to maintain him after release. Following initiation of the prolixin regime, Rennie's condition did improve markedly.

Judge Brotman responded to Rennie's appeal for an injunction by issuing a compromise ruling. Rather than enjoining the hospital from giving him any medication, he insisted that the prolixin be lowered to a minimum maintenance dosage, which staff psychiatrists considered too low. He then conducted fourteen days of hearings between January 13 and April 28, 1978.

Several months after issuing his initial ruling that asserted a right to refuse treatment grounded in a constitutional right to privacy, Judge Brotman made the case into a class action that included all involuntarily committed patients at the five mental health facilities operated by the state of New Jersey, and held an additional seventeen days of hearings.