Summary
The D.C. Circuit held that a District of Columbia policy requiring full restraints (handcuffs, waist chain, leg restraints) on civilly-committed forensic patients during transport to court hearings did not violate the Fifth Amendment due process right to be free from unjustified bodily restraint. Applying both the Bell nonpunitive purpose test and the Youngberg professional judgment standard, the court found the policy was reasonably related to legitimate security interests (preventing injuries, escapes, and safeguarding the public) and was not a substantial departure from accepted professional standards. The court rejected the plaintiff's challenge to the blanket policy, deferring to the professional judgment of the Department of Behavioral Health's Chief Nurse Executive who approved the policy. *Warren Harris v. Muriel Bowser*, 2023 WL 2306820 (D.C. Cir. 2023).
Topics
Practice areas
Questions Presented
- Whether the District of Columbia's policy of restraining civilly-committed patients during transport violated Harris's Fifth Amendment due-process rights.
Holdings
- Under Bell, restrictions must be reasonably related to a legitimate nonpunitive government objective and not excessive. Here, the policy was reasonably related to maintaining security and was not excessive, as full restraints are common practice.
- Under Youngberg, a decision to restrain a civilly-committed patient is presumptively valid if made by a professional and not a substantial departure from accepted professional judgment. The policy here was made by a professional (the Chief Nurse Executive) and was not a substantial departure.
Key quotations
“core of the liberty protected by the Due Process Clause is the liberty from bodily restraint” (at 316)
“reasonably related to a legitimate government objective” (at 539)
“not absolute” (at 320)
Factual background
The District of Columbia Department of Behavioral Health had a policy requiring the Department of Corrections to transport civilly-committed forensic detainees in full restraints (handcuffs, waist chain, leg restraints) during court hearings. Warren Harris, a civilly-committed patient, was restrained under that policy during transport to a conditional release hearing. His belt was also removed, forcing court staff to help him hold up his trousers. After the hearing granted him conditional release, Harris sued under 42 U.S.C. § 1983.
Procedural history
Harris filed a § 1983 suit alleging that the District of Columbia's policy of restraining civilly-committed patients during transport violated his Fifth Amendment due-process rights. The district court granted summary judgment for the defendants. Harris appealed.