Court Case Documentation

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Case Name            Halderman vs. Pennhurst

Docket / Court        74-1345 ( E.D. Pa. )

State/Territory        Pennsylvania

Case Summary     

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 defendants’ 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     

  

Documentation

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