The following excerpt is from Cruz v. Ward, 558 F.2d 658 (2nd Cir. 1977):
I understand my brothers' reluctance to question the professional judgment of psychiatrists. Nevertheless, until now, courts have not been dissuaded from investigating a possible denial of due process simply because a doctor or psychiatrist is involved. Surely it is too late in the day to argue that a mere unarticulated medical judgment, without a written statement of reasons that can withstand judicial scrutiny, is sufficient to support a decision to commit a prisoner to an insane asylum. Cf. U. S. ex rel. Schuster v. Herold, supra. We cannot blind ourselves to the deplorable condition of many mental hospitals and the shocking practices revealed in the record before us. When one of the staff physicians at Matteawan testifies that only a uniform "manual of procedures" will prevent further proliferation of the "slipshod" practices that ensue from the unstructured exercise of individual discretion, it surely will not do for a federal court to rely upon "professional judgment" without more.
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