Healey v. Spencer, 765 F.3d 65 (1st Cir. 2014)
Nature of Case: Two individuals who had been designated under Massachusetts law as “sexually dangerous persons” and therefore civilly committed to the Massachusetts Treatment Center brought a civil rights lawsuit alleging that the treatment and conditions that they were subjected to violated a management plan that was the product of long-running litigation involving the center. Appellants also alleged that lack of adequate treatment violated Substantive Due Process rights. District Court found that the plan constituted an enforceable court order, and also found Substantive Due Process violations as to Appellants. Parties cross-appealed.
Holding: 1st Circuit Court of Appeals reversed in part and affirmed in part, finding that the plan was not an enforceable court order and that–apart from inadequate pharmacological treatment–there was no Due Process violation.