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Schmidt v. Lessard
Citations: 38 L. Ed. 2d 661; 94 S. Ct. 713; 414 U.S. 473; 1974 U.S. LEXIS 40; 18 Fed. R. Serv. 2d 13Docket: 73-568
Court: Supreme Court of the United States; January 14, 1974; Federal Supreme Court; Federal Appellate Court
Alberta Lessard was involuntarily committed under the Wisconsin State Mental Health Act in 1971 and subsequently filed a lawsuit in the U.S. District Court for the Eastern District of Wisconsin. She claimed that the state's involuntary commitment laws violated the Due Process Clause of the Fourteenth Amendment, seeking declaratory and injunctive relief for herself and others similarly situated. A three-judge District Court found the Wisconsin statutory scheme unconstitutional and granted Lessard and her class both declaratory and injunctive relief. Nine months later, the court issued a judgment confirming its earlier opinion. The defendants appealed to the Supreme Court, invoking appellate jurisdiction under 28 U.S.C. 1253. Lessard moved to dismiss the appeal, arguing that the District Court's judgment did not constitute an order granting or denying an injunction, citing precedent from Gunn v. University Committee to End the War. However, the Supreme Court noted a critical distinction: while the Gunn case lacked a formal order granting injunctive relief, the current case had a judgment that expressly followed the opinion granting such relief. The Supreme Court acknowledged its jurisdiction under 28 U.S.C. 1253 but criticized the District Court's order as insufficient for comprehensive judicial review, referencing Rule 65(d) of the Federal Rules of Civil Procedure, which mandates that injunctions must clearly articulate the reasons for issuance and specify the acts to be restrained. The order fails to meet the specificity requirements of Rule 65(d) regarding injunctive relief, lacking clear terms or detailed descriptions of the conduct being restrained. Defendants are merely instructed not to enforce the existing Wisconsin scheme against the appellee's class, which does not provide the necessary clarity. Rule 65(d) aims to prevent confusion for those under injunctions and to ensure that contempt citations are based on clear decrees. Specificity is essential for the fairness of the injunction and for effective appellate review; without it, understanding the bounds of the District Court's judgment is hindered. Consequently, the appellate court vacates the District Court's judgment and remands the case for further proceedings. The lack of a specific order has led to confusion, evidenced by a request for clarification from both parties, which remains unaddressed by the District Court, possibly due to the pending appeal. The judicial contempt power must be exercised based on clear directives to avoid the risks associated with vague orders.