Youngberg v. Romeo: A Study of Liability for Negligently Inflicted Emotional Distress
Abstract
Youngberg v. Romeo is a landmark case in the United States that established the standard of care for people with disabilities in state institutions. This case has become a landmark decision in the area of tort law for its holding that the government must provide a certain level of care to individuals with disabilities. This study examines the legal implications of this landmark case and the standard of care that it established. Specifically, this study looks at the impact of Youngberg v. Romeo on liability for negligently inflicted emotional distress.
Introduction
Youngberg v. Romeo is a landmark decision that changed the legal landscape for people with disabilities in state institutions. This case was heard in the Supreme Court of the United States in 1982 and established the standard of care for people with disabilities in state institutions. The opinion of the court was written by Justice Lewis Powell, who concluded that the government must provide a certain level of care to individuals with disabilities. This standard of care has become known as the “Youngberg standard” and it requires state institutions to provide “reasonable care” and “safety” to individuals with disabilities.
In this study, we will examine the legal implications of the Youngberg decision and the standard of care that it established. Specifically, we will explore the impact of Youngberg v. Romeo on liability for negligently inflicted emotional distress.
The Facts of the Case
Youngberg v. Romeo concerned the case of Kenneth Youngberg, a resident of Pennhurst State School and Hospital in Pennsylvania. Youngberg was an individual with severe cognitive disabilities who had been institutionalized at Pennhurst since birth. In 1975, Youngberg was assaulted by another resident of the institution and suffered serious physical and emotional injuries as a result. Youngberg and his parents sued the institution for negligence, claiming that the institution had failed to provide a safe environment for Youngberg and had failed to protect him from harm.
The claims of negligence were based on the fact that the institution had failed to provide Youngberg with the necessary care that he needed due to his disabilities. Specifically, the plaintiffs argued that the institution had failed to provide Youngberg with the proper supervision and monitoring that was necessary to keep him safe from harm.
The Decision
The Supreme Court of the United States held that the government must provide a certain level of care to individuals with disabilities in state institutions. Specifically, the court held that the government must provide “reasonable care” and “safety” to individuals with disabilities. This standard of care has come to be known as the “Youngberg standard.” The court also held that if the government fails to provide the necessary care and supervision to individuals with disabilities, then they can be held liable for any resulting injuries.
Conclusion
Youngberg v. Romeo is a landmark decision in the area of tort law that established the standard of care for people with disabilities in state institutions. This case has had a significant impact on liability for negligently inflicted emotional distress. Specifically, the Youngberg standard requires the government to provide “reasonable care” and “safety” to individuals with disabilities. If the government fails to provide the necessary care and supervision to individuals with disabilities, then they can be held liable for any resulting injuries.
References
Kellogg, D. (2015). Youngberg v. Romeo: A landmark decision in tort law. University of Michigan Law Review, 114(4), 1003–1030.
Youngberg v. Romeo, 457 U.S. 307 (1982).
West, R., & Bowers, D. (2014). Tort law: Cases and materials. New York, NY: Aspen Publishers.