Dennis Strutton v. Linda Meade, 668 F.3d 549

Strutton, a civilly committed resident of MSOTC, sued under 42 U.S.C. § 1983 alleging due process violations related to treatment access and disciplinary measures.
MSVPA/Missouri statute authorize confinement for ongoing control, care, and treatment until change in mental abnormality allows safe release; MSOTC conducts annual evaluations for release determinations.
MSOTC’s treatment program has four phases with process groups; participation is encouraged but not strictly required for progress.
Budgetary constraints and staffing shortages in 2006–2007 led MSOTC to modify psychoeducational offerings, downsize groups, and shift to larger process groups; process groups were reduced in frequency.
MSOTC implemented disciplinary measures, including the Restriction Table (later a Restriction Area), linking violations to progress level setbacks and restricted movement, though residents were not physically restrained.
Strutton’s treatment participation waned; he contested treatment reforms and claimed the disciplinary measures were constitutionally defective and that their modifications damaged his progress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing and mootness of treatment and discipline claims	Strutton’s injury is ongoing and redressable; mootness not met.	No ongoing injury and moot; claims should be dismissed.	Claims not moot; standing established; injury traceable and redressable.
Fundamental right to treatment and applicable standard	Youngberg professional judgment standard should apply.	No fundamental right to treatment; apply conscience-shocking standard.	No fundamental right; conscience-shocking standard applies.
Disciplinary measures and progress impact under due process	Restriction Table/Area adversely affected progress and shocked conscience.	Disciplinary measures were not arbitrary or egregious and allowed movement and activities.	No conscience-shocking violation; restrictions did not shock the conscience.
Spoliation sanctions for destroyed emails and records	Defendants failed to preserve evidence; sanctions warranted.	No bad faith or prejudice; sanctions not warranted.	District court did not abuse discretion; sanctions denied.

Sierra Club v. U.S. Army Corps of Eng’rs, 645 F.3d 978 (8th Cir. 2011) (standing requires injury, causation, redressability)
Spencer v. Kemna, 523 U.S. 1 (1998) (standing, injury, and redressability framework)
Youngberg v. Romeo, 457 U.S. 307 (1982) (professional judgment standard for treatment; safety and reasonable care)
Elizabeth M. v. Montenez, 458 F.3d 779 (8th Cir. 2006) (no substantive due process right to treatment absent egregious conduct)
Bailey v. Gardebring, 940 F.2d 1150 (8th Cir. 1991) (no constitutional right to psychiatric treatment for pedophilia)
Kansas v. Hendricks, 521 U.S. 346 (1997) (detention without treatment does not violate constitution)
United States v. Salerno, 481 U.S. 739 (1987) (substantive due process shocks the conscience standard)
Martin v. Sargent, 780 F.2d 1334 (8th Cir. 1985) (equitable relief and continuing confinement issues)