686 F. App'x 3
D.C. Cir.2017Background
- Y.F., a minor, was taken into the District of Columbia Child and Family Services Agency (CFSA) custody by court order in 2006 due to Jordan’s neglect.
- A subsequent court order placed Y.F. at the Psychiatric Institute of Washington (PIW) for psychiatric treatment.
- Medical professionals at PIW determined Y.F. needed antipsychotic medication and administered it after obtaining consent from CFSA (the custodial agency), not from Jordan.
- Jordan and Y.F. sued, alleging a due process violation for administering antipsychotic drugs without Jordan’s consent.
- The District Court granted summary judgment to the District of Columbia and PIW on the due process claim.
- The D.C. Circuit affirmed, concluding appellees’ conduct did not constitute a substantial departure from professional judgment or deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether administering antipsychotic medication to a child in state custody without parental consent violated due process | Jordan: administering meds without her consent violated Y.F.’s liberty interest unless treatment was consistent with professional judgment or parental rights were respected | Appellees: CFSA had custody and provided consent; treatment was medically appropriate and consistent with professional judgment | Court: No due process violation — treatment was appropriate and CFSA consented |
| Whether the conduct amounted to "substantial departure" from accepted professional judgment or "deliberate indifference" | Jordan: nonconsensual administration that departs from standards or is indifferent to rights triggers due process protection | Appellees: record shows expert support for the medications and proper consent procedures, so no substantial departure or deliberate indifference | Court: Actions did not meet either standard; summary judgment for defendants affirmed |
Key Cases Cited
- Washington v. Glucksberg, 521 U.S. 702 (recognition of protected liberty interests under Due Process)
- Washington v. Harper, 494 U.S. 210 (government may be constrained by due process when administering antipsychotics to those in custody)
- Youngberg v. Romeo, 457 U.S. 307 (standard: professional judgment governs state care decisions)
- Smith v. District of Columbia, 413 F.3d 86 (D.C. Cir. 2005) (deliberate indifference standard in custodial medical-treatment claims)
- Abdelfattah v. Department of Homeland Security, 787 F.3d 524 (D.C. Cir. 2015) (only egregious official conduct violates Due Process)
- Jordan v. District of Columbia, 161 F. Supp. 3d 45 (D.D.C. 2016) (district court decision granting summary judgment to defendants)