The right to treatment of the institutionalized mentally ill in the United States

: In his epochmaking article, Birnbaum proposed that courts should recognize a right to treatment of institutionalized psychiatric patients based on the substantive due process. His proposal was adopted in Rouse v. Cameron as a statutory right. Wyatt v. Stickney decision was the first to hold that there was a constitutionally based right to treatment for involuntarily committed patients. The Supreme Court, though reluctantly, held in Youngberg v. Romeo that the institutionalized mentally retarded were entitled to minimally adequate training, which was drawn in the Fourteenth Amendment.