Youngberg v. Romeo, 457 U.S. 307 (1982) (Supreme Court of the United States)
Youngberg v. Romeo is a landmark substantive due process case defining the constitutional rights of individuals who are involuntarily committed to state institutions because of intellectual or developmental disabilities.
What substantive due process rights do involuntarily committed persons hold regarding safety, bodily restraint, and training, and what standard governs judicial review of professional decisions in state institutions when those rights are alleged to have been violated?
Under the Fourteenth Amendment's Due Process Clause, an involuntarily committed person has liberty interests in reasonably safe conditions of confinement and freedom from unreasonable bodily restraints. The person also possesses a right to minimally adequate or reasonable training when such training is necessary to ensure safety and freedom from undue restraint. In evaluating whether state officials have violated these rights, courts must defer to the decisions of qualified professionals; liability may be imposed only when the decision by a professional is such a substantial departure from accepted professional judgment, practice, or standards as to demonstrate that the decision was not based on professional judgment.
The Court held that Romeo had constitutional liberty interests in reasonable safety, freedom from unreasonable restraints, and minimally adequate training necessary to secure those rights. The appropriate standard for assessing alleged violations is deference to the professional judgment of qualified personnel, with liability only upon a substantial departure from accepted professional standards. The Court rejected a strict least-restrictive-alternative mandate and remanded for application of the professional judgment standard.
Youngberg is the foundational case for conditions-of-confinement claims by civilly committed individuals. It establishes (1) concrete substantive due process rights to safety and freedom from unreasonable restraints; (2) a limited right to training necessary to secure those rights; and (3) a deferential liability standard that protects professional discretion while guarding against egregious departures from accepted practice. For law students, the case is crucial to understanding how the Constitution operates outside the criminal context, how § 1983 claims are framed for civil detainees, and how courts balance individual liberty with institutional expertise and resource constraints. The professional judgment standard continues to guide litigation involving psychiatric facilities, developmental disability institutions, and other civil detention settings.