The Fine Line: Involuntary Commitment, Patient Rights, and the Case of Kenneth Donaldson

Involuntary commitment can often provide help to those who are unable to access it or are unaware that they need it. (Getty Images)

By Evie Diffloth on April 4th 2025

In 1957, Kenneth Donaldson was taken away to a mental institution, thinking that he would stay for just a few weeks, in accordance with the judge’s mandate. Instead, he would remain in confinement for fifteen years, most of which would be spent alone, locked in a room devoid of meaningful treatment or human connection. Kenneth Donaldson was involuntary committed to a psychiatric hospital on January 3rd, 1957, and was not released until July 31, 1971. The Donaldson case serves as a striking instance of the abuses that can occur as a result of involuntary commitment, and the thin line between providing necessary care and violating individual rights.

Involuntary commitment, sometimes referred to as civil commitment, is a legal process in which a person who has been found to have a severe mental health condition is sent to a psychiatric hospital for treatment without their consent. In order for an individual to be committed involuntarily, a number of criteria must be met, starting with having a serious mental disorder that affects one’s behavior, mood, judgement, and perception. The person’s symptoms must pose an immediate danger to themselves or to someone else, as well as prevent them from fulfilling simple personal tasks, like purchasing food, obtaining shelter, and accessing medical care. The final criterion is that the individual would benefit from treatment at a psychiatric hospital for their condition. If a person meets all of these criteria, they are eligible to begin the process of involuntary commitment.

The process of civil commitment begins with a healthcare or mental health provider, social worker, or law enforcement officer placing an emergency psychiatric hold on an individual, which allows for evaluation of whether the person is eligible for involuntary commitment. A police officer takes the individual into custody on an emergency hold, transporting them to a secure location, often a hospital emergency room, to be evaluated. The person is then assessed by a mental health professional, who determines if the individual meets the criteria for involuntary commitment, which usually involves interviewing the person and family members or friends, as well as reviewing the person’s medical records and reports if available. If the pre-screening report submitted to the judge or magistrate by the mental health professional advises commitment, and the judge or magistrate agrees, the court issues an order for the individual to be involuntarily hospitalized while awaiting a formal hearing. The magistrate is a type of judge, that handles minor legal matters, pretrial hearings, and administrative duties, and a hearing is a formal legal proceeding where parties present evidence and arguments in front of a judge or magistrate. Following this, the individual is transported to a facility, where a formal commitment hearing is held, and if the judge upholds the decision to commit the person, they are committed to inpatient care for a set duration. Staff at the psychiatric hospital can release an individual before their commitment term is over if they deem them to be mentally stable, or they can request a recommitment hearing if the person’s mental state has not improved within the given time frame.

Involuntary commitment protects those with mental illness from harm, but simultaneously raises serious ethical concerns. In removing the patient’s choice as to whether or not they are committed to a psychiatric hospital, involuntary commitment sacrifices the autonomy of patients and prioritizes beneficence, a healthcare worker’s duty to act in a way that benefits the patient. Committing patients with substance use disorders or other severe mental health conditions improves their well-being by preventing further harm being done to their physical, emotional, and social health. One perspective is that the ethical question of whether it is moral to hold a patient against their will is largely dependent on the effectiveness of the treatment and whether the patient’s situation improves as a result of being hospitalized. Studies on this subject have produced mixed results, and there is little data available tracking utilization of involuntary commitment for mental health conditions, making it difficult to determine the actual benefit to patients.

Over the years, many cases have challenged the scope of laws governing involuntary commitment, leading to changes in policy and legal standards. One notable case was that of O'Connor v. Donaldson, in which Kenneth Donaldson was committed to Florida State Hospital after a short hearing before a county judge, where he was diagnosed with paranoid schizophrenia. The judge who decided on Donaldson’s commitment had said that he would only be treated at the hospital for a few weeks, but in the end Donaldson was detained for a duration of fifteen years. J.B. O’Connor was the Assistant Clinical Director of the hospital at the time, as well as Donaldson’s attending physician. John Gumanis, a physician in Donaldson’s ward, did not allow Donaldson grounds privileges, confining him to a locked building. Donaldson received cognitive therapy from O’Connor only six times during his commitment, with the hospital providing a very minimal level of psychiatric treatment. While Donaldson attempted to challenge his continued commitment on many occasions, each time he was denied, with little explanation as to why. After finally being released, Donaldson charged O’Connor and other hospital staff members with intentionally and maliciously denying him his right to personal liberty. At the trial, the evidence demonstrated that the hospital staff held the power to discharge a mentally ill patient who had been committed if they did not pose a threat to themselves or other people, but the staff instead chose not to exert this power. The jury decided in favor of Donaldson, considering both compensatory damages, money awarded to compensate a victim for losses suffered due to another party’s harmful actions, and punitive damages, money awarded to punish the defendant for reckless or malicious actions, against O’Connor and Gumanis. O’Connor appealed his case separately, and the US Court of Appeals for the Fifth Circuit upheld the jury’s decision, rejecting O’Connor’s justification that he had been acting with good intentions and for the benefit of Donaldson’s health and well-being. This case had an important impact on shaping the interpretation of commitment laws, cementing that individuals cannot be involuntarily committed if they are not dangerous and can survive safely outside a psychiatric hospital.

Since its initial applications in the 19th century, involuntary commitment has provided psychiatric treatment to those who need it but are unable to or do not want to access it, helping to protect themselves as well as others. Currently, the equilibrium between providing necessary mental health care and protecting individual rights continues to shape the ongoing evolution of involuntary commitment laws and practices. Balancing individual rights and public safety is like walking a tightrope– lean too far in one direction, and we risk either harm or oppression. The challenge is not just staying upright, but making sure no one falls.