Is there a federal right to treatment for a mentally ill person?

The theory of a federal right to treatment rooted in the due process clause was fully developed in Donaldson v. O'Connor (5th Cir.1974) 493 F.2d 507. In that case, the plaintiff had been involuntarily incarcerated in a state-owned-and-operated mental institution for nearly 15 years. Uncontradicted testimony indicated that he was not dangerous and could survive responsibly on his own or with the aid of others. During his incarceration, he received virtually no treatment. (Id., at pp. 510-511, 517.)