Townsend v. Department of State Hospitals
- Edward Chen
- 3:21-cv-02055
- U.S. District Court · Northern District of California
- 5
In Townsend v. Department of State Hospitals, Judge Hixson allowed Townsend’s forced-medication claim to proceed, denied his property request, and ordered service.
The order allows Rebio Ronnie Townsend’s § 1983 due-process claim concerning forced psychiatric medication to proceed against R. Brar, while denying Townsend’s separate request concerning a confiscated letter.
What happened
In Townsend v. Department of State Hospitals, Rebio Ronnie Townsend, who is being held at Napa State Hospital, sued under a federal civil-rights law. He alleged that psychiatrist R. Brar forced him to take unnecessary psychiatric medication even though he was not mentally ill or dangerous.
The court found that the complaint described a recognizable claim that forced medication violated Townsend’s right to make decisions about his own body. The court denied Townsend’s separate request for the return or value of a letter, because that request was outside this case, which concerns forced medication.
Judge Thomas S. Hixson ordered the complaint to be served on R. Brar, set deadlines for future motions, and denied the property request. The case therefore proceeds on Townsend’s forced-medication claim; the court did not decide whether that claim will ultimately succeed.
The detailed version
- Townsend v. Department of State Hospitals · No. 3:21-cv-02055
- Edward Chen
- Apr. 19, 2021
Background
Rebio Ronnie Townsend, an inmate at Napa State Hospital, filed a self-represented action under 42 U.S.C. § 1983. The court screened the complaint under 28 U.S.C. § 1915A, which requires preliminary review of a prisoner’s claims against a governmental entity or government officer. Townsend had also been granted permission to proceed without paying filing fees in a separate order.
Townsend alleged that, since about late January 2021, Department of State Hospitals psychiatrist R. Brar had forced him to take unnecessary psychiatric medication. Townsend alleged that he was not mentally ill or dangerous and that the medication was not needed. He sought $20 million in damages.
Forced-medication claim
The court held that the complaint stated a cognizable due-process claim against R. Brar. The court explained that forcibly injecting medication into a nonconsenting person substantially interferes with liberty and that the Fourteenth Amendment protects a significant liberty interest in avoiding unwanted antipsychotic medication. The court did not decide the ultimate merits of the claim.
Confiscated-property request
Townsend separately alleged that he mailed a letter on March 19, 2021, that Brar opened it, that Townsend received a copy on March 23, 2021, and that Brar would not return the original. Townsend asked the court to order the letter’s return or reimburse him for its value.
The court denied that motion because it was outside the scope of this action. The court stated that this action seeks relief related to forced medication. The order terminated the property motion, docket entry 9.
Service and next steps
The court ordered the Clerk to issue a summons and directed the United States Marshal to serve the complaint and the order on R. Brar without prepayment of fees. The court also directed that a courtesy copy be sent to the California Attorney General’s Office.
The order required the defendant, within 91 days after filing of the order, to file and serve a summary-judgment motion or another dispositive motion, or inform the court if summary judgment could not resolve the case. Townsend’s opposition would be due 28 days after the motion, and the defendant’s reply would be due 14 days after the opposition. The order also addressed discovery, service of filings, address changes, prosecution of the case, and requests for extensions of time.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.