Donaldson held 15 years at Chattahootchee State Hospital, but refused all treatment as a "Christian Scientist." Got "Milieu Treatment." Had worked for 13 yrs prior to commitment, had friends who would take him, was not dangerous.
Started as Class Action, dropped to individual suit.
Trial Court awarded compensatory & punitive damages against Superintendent O'Connor & psychiatrist. Court of Appeals said "only purpose of commitment is treatment, and pt has a CONSTITUTIONAL right to treatment," based on WYATT. See also O'Connor v. Donaldson.