This case was a class action suit on the behalf of children with mental retardation and mental illness who were living in the Partlow state school in Alabama. The children living in this institution were not afforded access to an educational program. The parents of Ricky Wyatt, a resident, joined other parents in this suit. After hearing testimony from expert witnesses, Partlow employees and administrators, and others, the court found that children living in the Partlow state school were entitled to a right to treatment that included education.
The court stated that persons with mental retardation were guaranteed a right to treatment and education under the law. The court summed this right up in the following statement:
"...since the only constitutionally justification for civilly comitting a mental retardate (sic) is habilitation, it follows that once committed, they possess an involuable right to habilitation (that includes education and treatment)"
The court went on to deliniate 49 standards that constitute minimally adequate habilitation (education, training, freedom from aversive behavioral interventions, limited use of pharmacological agents to control behavior, a proscription on the use of restraints, and others).
The significance of this case is that the Wyatt decision was the first decision finding that persons with disabilities had a Contitutional right to treatment (substitute education). Unfortunately, this case continued to be contested through appeals for over 13 years. I am not sure that the court mandated changes have ever been fully implemented.