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Case Name Halderman vs. Pennhurst
Docket / Court 74-1345 ( E.D. Pa. )
In May of 1974, plaintiffs filed a class-action lawsuit on behalf of former
and present residents of Pennhurst
School and Hospital, a state institution for persons with retardation in Spring
City, Pennsylvania, against officials of the State of Pennsylvania. In 1975, the
Pennsylvania Association for Retarded Citizens (ARC/PA) and other organizations
intervened as plaintiffs, adding as defendants the Mental Health/ Mental
Retardation Administrators of Bucks, Chester, Delaware, Montgomery, and
Philadelphia Counties. The United States of America also intervened as a party
plaintiff. Plaintiffs were represented by private attorneys and ARC/PA was
represented by the Public Interest Law Center of Philadelphia. In November of
1976, the class was certified and the case went to trial in the following year.
In its Findings of Fact and Conclusions of Law, the district court (Judge
Raymond J. Broderick) reported that Pennhurst was overcrowded, understaffed, and
lacked programs necessary for adequate habilitation. Halderman v. Pennhurst
State Sch. & Hosp., 446 F.Supp. 1295 (E.D. Pa. 1977). The court also found that
restraints and psychotropic drugs were used as control measures. Residents
suffered injuries from abuse by staff and other residents.
In 1984, after several years of litigation and many published opinions, the parties reached a settlement. The district court (Judge Broderick) held a hearing and approved the consent decree on April 5, 1985. Halderman v. Pennhurst State Sch. & Hosp., 610 F.Supp. 1221 (E.D. Pa. 1985). According to the agreement, the Pennsylvania state and county defendants agreed, among other things, to provide community living arrangements to plaintiffs where appropriate, as determined through an individualized planning process. The court noted that all parties agreed that Pennhurst was not an appropriate facility for habilitation of mentally retarded individuals. Subsequent court opinions reported that former Pennhurst residents who were moved into community placements made significant improvements in life skills. See, e.g. Halderman v. Pennhurst State Sch. & Hosp., 154 F.R.D. 594, 597 (D. Pa. 1994).
The plaintiffs filed many motions to enforce the settlement agreement and defendants were found to be noncompliant in the years following the agreement. Most noncompliance resulted from a lack of individualized services to all plaintiffs. On March 28, 1994, the court found the state in contempt and directed it to take specific actions to remedy the noncompliance. Halderman v. Pennhurst State Sch. & Hosp., 154 F.R.D. 594 (D. Pa. 1994). The court appointed a Special Master, Tony Records, to monitor compliance. According to a report of the Special Master in 1998, there were significant improvements in the defendantsí fulfillment of their obligations under the 1985 agreement. In 1998, the district court (Judge Broderick) purged defendants of all contempt from the 1994 order and ordered the Office of the Special Master closed. The court recognized that improvement was still needed but that the defendants had submitted plans to the court and further court supervision was unnecessary. Halderman v. Pennhurst State Sch. & Hosp., 9 F.Supp.2d 544 (E.D. Pa. 1998). Pennhurst Center is no longer in operation.
-Angela Heverling - 05/27/2007
Docket 81-2101 (U.S. Court of Appeals) 2/22/1983
Docket 74-1345 (E.D. Pa) 8/1/1995 - Large .PDF - Please be patient as this will take a bit to load
First Amended Complaint (Class Action) 7/29/1974
Memorandum Decision 10/20/1980
Memorandum Decision 10/30/1980
On Writ of Certiorari : Appendix 1/1/1983 - Excellent summary with complete references detailing the facts behind the Pennhurst case.
For the complete listing of all documents pertaining to the Pennhurst case, please visit the Civil Rights Litigation Website