Commissioner of Correction v. Coleman
38 A.3d 84
Conn.2012Background
- Coleman, an inmate, initiated a hunger strike in 2007, resulting in significant weight loss and health risk.
- The Commissioner sought a permanent injunction authorizing forcible restraint and feeding (via nasogastric tube and IV) to prevent death or permanent harm.
- Trial court found Coleman mentally competent, not suicidal, and that his protest aimed to publicize perceived judicial-system failures.
- Medical staff monitored him; IV fluids and nasogastric feeding were employed after his health deteriorated, with other nutrition attempts attempted first.
- Trial court concluded the state had interests in preserving life, preventing suicide, protecting third parties (his children), and maintaining prison security, outweighing bodily integrity claims.
- Court of appeals affirmed; issue on appeal is whether these interests justify force-feeding against Coleman’s bodily autonomy, and whether international law prohibits it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state interests outweigh bodily integrity | Lantz: interests in life, suicide prevention, third-party protections, and prison security outweigh Coleman's right | Coleman: bodily integrity outweighs state interests; force-feeding invasive | Yes; interests outweighed bodily integrity; injunction upheld |
| Whether force-feeding violates First/Fourteenth Amendment | Lantz: force-feeding reasonable under Turner to prevent harm and uphold penology | Coleman: violates right to privacy and free speech; forced medical treatment | No; Turner factors satisfied; rights not violated |
| Whether international law prohibits force-feeding | Lantz: intl law may inform but not bind; no consensus banning force-feeding | Coleman: intl authorities prohibit force-feeding | No; international law does not prohibit medically necessary force-feeding; affirmed |
Key Cases Cited
- Stamford Hospital v. Vega, 236 Conn. 646 (1996) (bodily integrity and informed consent; prison context balancing)
- McNabb v. Dept. of Corrections, 163 Wash.2d 393 (2008) (state interest in preserving life; force-feeding restores health)
- In re Caulk, 125 N.H. 226 (1984) (state interest in life and preventing suicide overrides prisoner autonomy)
- Hill v. Dept. of Corrections, 992 A.2d 933 (Pa.Commw.2010) (health imminence; conditional allowance of force-feeding)
- Thor v. Superior Court, 5 Cal.4th 725 (1993) (life quality and state interest; duty to patient autonomy)
- Singletary v. Costello, 665 So.2d 1099 (Fla.App.1996) (guarded view on life preservation vs suicide prevention)
- Zant v. Prevatte, 248 Ga. 832 (1982) (suicide prevention and life preservation balance)
- Turner v. Safley, 482 U.S. 78 (1987) (four-factor test for reasonable relationship to penological interests)
- Roque v. Warden, 181 Conn. 85 (1980) (prison rights; special considerations in prison context)
- Stamford Hospital v. Vega, 674 A.2d 821 (1996) (health rights vs prison policy analysis)