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Follow up to Donaldson v. O'Connor. Supreme Court side-stepped right to treatment question, saw this as liberty issue only. Used the phrase, "can't commit without more." ?? what they meant by 'more.' Said superintendent NOT personally responsible unless he knew or was malicious. Vacated damages against O'Connor. Limits the right of the State to commit & confine; put Mental illness under Fed. Civil Rights statute. See also Vitek v. Jones