| Parham v. J.R. | |
|---|---|
 | |
| Argued October 10, 1978 Decided June 20, 1979 | |
| Full case name | Parham v. J.R. |
| Citations | 442 U.S. 584 (more) 99 S. Ct. 2493; 61 L. Ed. 2d 101 |
| Case history | |
| Prior | Judgment for plaintiffs, 412 F. Supp. 112 (M.D. Ga. 1976), probable jurisdiction noted, 431 U.S. 936 (1977). |
| Holding | |
| (1) Georgia's procedures for committing a child to a state mental hospital are not constitutionally deficient because the Constitution requires that parents are presumed to act in the best interest of their children. This presumption may only be rebutted, and the state may only intervene in a parental decision, if it is proven that a parent has neglected or abused their child. (2) The Due Process Clause requires that a "neutral factfinder" must periodically review a child's continued commitment to a state mental hospital upon parental request. However, the factfinder is not required to be trained in law, nor is the proceeding required to be an adversary hearing. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Burger, joined by White, Blackmun, Powell, Rehnquist |
| Concurrence | Stewart |
| Concur/dissent | Brennan, joined by Marshall, Stevens |
| Laws applied | |
| U.S. Const. amend. XIV | |
Parham v. J.R., 442 U.S. 584 (1979), was a United States Supreme Court case that reviewed Georgia's procedures for the commitment of a child to a mental hospital based on the request of a parent. The Court rejected, by a vote of 6–3, a class-action lawsuit from a group of minors, who claimed that the state's procedures were insufficient to ensure that parents did not use state mental hospitals as a "dumping ground" for children, and to ensure that minors committed to mental hospitals by their parents actually suffered from a condition sufficient to justify commitment.[1] In so doing, the Court reversed a lower court ruling holding numerous aspects of the Georgia mental health system unconstitutional.
- ^ "Appellees, children being treated in a Georgia state mental hospital, instituted in Federal District Court a class action against Georgia mental health officials. Appellees sought a declaratory judgment that Georgia's procedures for voluntary commitment of children under the age of 18 to state mental hospitals violated the Due Process Clause..." Parham, 442 U.S. at 584.