Court Backs State on Mental Health : Rejects Suit Challenging Legality of Some Hospitalizations

A Los Angeles Superior Court judge Monday upheld the state’s management and funding of mental health care, ending a legal challenge claiming patients were unconstitutionally hospitalized when they should be treated in community settings.

The 13-page written decision by Los Angeles Superior Court Judge Max F. Deutz ended a 6-year-old class-action civil suit brought by state and county mental health associations after former Gov. Edmund G. Brown Jr. reduced his proposed 1979-80 budget for community treatment facilities from $160 million to $24 million.

The mental health advocates agreed with state officials’ plan to shift care to community facilities, but claimed the state failed to fund those facilities, wrongly relying on hospitalizing mentally ill patients.

The suit sought court orders freezing expansion of state mental hospitals and forcing the state and Los Angeles County to fund and develop alternatives to Metropolitan and Camarillo hospitals. The alternatives would include community-based clinics, halfway houses, hostels, day treatment centers and outpatient centers.

But Deutz noted that no state is legally required to provide mental health services and that, if it does, it has great leeway in deciding the scope of the services.

“To pass constitutional muster relative to the operation of the state’s mental health system,” he wrote, “the executive and the legislative branches need only demonstrate that they have made reasonable decisions in their operation and administration.

“The evidence establishes that the executive and the legislative branches have made most reasonable decisions in the operation of the state’s mental health system.”

Currently, Deutz said, mental health care is a high state priority as indicated by Gov. George Deukmejian’s Mental Health Initiative and the work of the Assembly Select Committee on Mental Health. California compares favorably with other states in developing community health care, he said, ranking 13th in per capita spending for all mental health programs and 49th in the proportion of a state’s mental health budget spent on hospitals.

California spends 66.6% of its mental health budget on community programs and only 31% for hospitals, he said, while the top 10 states in population spend an average 66.8% of their total mental health budgets for state hospitals and 29.4% for community care.

“The funding of the mental health system has been commensurate with the state’s general fund budget,” Deutz decided, adding that it fared well compared to other programs without guaranteed cost-of-living adjustments. “The funding for the system has increased during good financial times and has decreased during hard times.”

Despite evident problems in the current system, Deutz said, the court should never intervene unless unconstitutional acts are found. He concluded that no patients involved in the court case had been unconstitutionally held in Camarillo or Metropolitan hospitals.

Evidence at the trial conducted last fall showed that Los Angeles County at any given time has about 1,050 chronically mentally ill persons at Camarillo and Metropolitan state hospitals, 11,000 in skilled nursing facilities, 450 in jail, 400 to 600 in local residential and hospital facilities, 4,000 in board and care facilities and an estimated 35,000 to 50,000 who receive no treatment, and risk being rehospitalized.