{"schema_version":"1.0","edition":"2026-10-07-through-batch-22","latest_batch":22,"rules":{"entry_is_not_episode":true,"candidate_is_not_finding":true,"duplicate_is_not_corroboration":true,"new_primary_verification_performed":false},"batches":[{"id":"BATCH-001","number":1,"summary":"Batch 1 (6 Oct 2026) lays the spine: the historical overview, landmark timeline entries, a first California register, a first international register, the mechanism synthesis, reforms, contrary evidence, and the bibliography. Later batches deepen decade by decade. Nothing here claims completeness; every coverage gap is named in section 9.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-002","number":2,"summary":"Batch 2 (6 Oct 2026) widens the mission from California to a worldwide record: a US national and state register, a worldwide register by region with local-language leads, and a geographic coverage index. Batch 1 content is preserved unchanged; California becomes one chapter.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-003","number":3,"summary":"Batch 3 (6 Oct 2026) opens the Batch 2 leads: a national US emergency-hold framework and six US state retaliation cases with jury findings; local-language passes for Korea, Japan, Spain and East Germany; Iran and the post-Soviet states; and a mechanism update. Coverage index status changes are listed under the index table.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-004","number":4,"summary":"Batch 4 (6 Oct 2026) opens Romania, Cuba, Australia and South Africa, adding a second \"complaint channel\" finding (Chelmsford) and a US federal jury finding on Cuban electroshock \\[corrected, Batch 18/D03: the 2002 conviction was for unlawful procurement of naturalization; what the jury found about electroshock is unestablished\\] torture (Mederos, 2002).","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-005","number":5,"summary":"Batch 5 (6 Oct 2026) adds the Southern Cone — Argentina, Chile and Uruguay — where the documented pattern is inverted: the dictatorships targeted the mental-health professions and used psychiatric labels inside prisons rather than confining dissidents in hospitals.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-006","number":6,"summary":"Batch 6 (6 Oct 2026) adds Turkey (forensic medicine used to keep prisoners in, not put them in), India (custodial neglect under court and NHRC monitoring), and the 22-country comparative data set that serves as the comparison set for \\[corrected, Batch 18/D06: observational, measures incidence not wrongful detention; \"control group\" withdrawn\\] the whole record: legal safeguards \\[withdrawn as a general claim, Batch 20/A04: an incidence comparison cannot show safeguards fail\\] do not predict detention rates.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-007","number":7,"summary":"Batch 7 (6 Oct 2026) resolves the Goldwater lead to VERIFIED from the American Journal of Psychiatry and JAAPL accounts and records it as the clearest US case of diagnostic discrediting adjudicated as actual malice.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-008","number":8,"summary":"Batch 8 (6 Oct 2026) adds Puerto Rico (first US territory researched), Belarus (UN-documented 33–37 punitive psychiatric sentences since 2020), Kazakhstan's Mukhortova case (a lawyer confined after complaining about a legislator, with a court citing her \"litigious\" activity as a ground), and the named diagnostic category that underwrites that logic: querulous paranoia (ICD-10 F22.8).","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-009","number":9,"summary":"Batch 9 (6 Oct 2026) verifies France's Claudel case against the Musée Camille Claudel chronology and the 1838 law's \"placement volontaire\" mechanism, closing the last of the Batch 2 European leads except Italy.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-010","number":10,"summary":"Batch 10 (7 Oct 2026) is the first run under the ten-channel method, applied to California: channel 3 (survivor archives) surfaced the pre-LPS Frank commitment and the Madness Network News / NAPA / Measure T line; channel 6 (adjacent instruments) surfaced jail suicide-watch findings, including a federal DOJ finding against Alameda County's John George hospital that upgrades the Batch 1 lead.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-011","number":11,"summary":"Batch 11 (7 Oct 2026) runs channel 1 on California — the statute name joined to *retaliation* and *First Amendment* — and finds the only California case in the record where a court actually reached the question of retaliatory motive for a § 5150 hold, and rejected it on the facts after trial.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-012","number":12,"summary":"Batch 12 (7 Oct 2026) runs channels 2 and 9 on California together: the patients'-rights complaint channel and the shape of what it reports upward.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-013","number":13,"summary":"Batch 13 (7 Oct 2026) begins the US state sweep at Arizona under the method: channel 1 (Title 36 procedure names in case law and session laws). Arizona's initiation rules are the loosest yet \\[corrected, Batch 18/D02: ranking withdrawn; the enacted 2024 law kept screening-agency filing\\] mapped in the United States and were amended (applicant notice and reasons; not loosened — corrected Batch 18/D02) in 2024.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-014","number":14,"summary":"Batch 14 (7 Oct 2026) runs channels 2, 4 and 6 on Arizona: the statutory oversight committee for the state hospital, the P&A litigation over access, and the historical federal investigation. The oversight channel yields a documented, recurring retaliation-for-grievance pattern at the Arizona State Hospital — the first US institutional instance of Mechanism 9 in the record.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-015","number":15,"summary":"Batch 15 (7 Oct 2026) opens Texas under channel 1 (Chapter 573 instrument names and session laws) and channel 2 (a municipal police-oversight complaint file). Texas shows a different design from Arizona: initiation is officer- and facility-led, and the legislature has explicitly carved the facility hold \\[corrected, Batch 18/D01: SB 359 was vetoed 2 Jun 2015; this describes a proposal, not law\\] out of the firearm-record consequence.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-016","number":16,"summary":"Batch 16 (7 Oct 2026) tests two of the revised-method corrections. The reverse sequence (start from known complainants) run on US protest activists returned no psychiatric instrument at all — a pattern finding in itself — and one Russian case missing from the register. The \"litigious as symptom\" archival question, run on US courts, returned a live mechanism the record had not yet named: civil-court competency inquiries under Rule 17(c) and vexatious-litigant orders, including one initiated by the opposing party.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-017","number":17,"summary":"Batch 17 (7 Oct 2026) is a cross-cut rather than a jurisdiction: channel 7 (timing) read back across every row in the record, plus one new witness case. It produces the first *interval* table — the distance in days between the speech act and the psychiatric act — and a pattern about how the law itself converts a hospitalization into impeachment.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-018","number":18,"summary":"Batch 18 (7 Oct 2026) is a correction batch. The parallel thread's edition 02 audited Batches 1–15 and found seven errors or overstatements (its items D01–D07) plus three carried from edition 01. Each is checked here against the primary text where possible, and the affected rows are amended rather than deleted so the error stays visible. Channel 10 (key cross-check) is then run on edition 01's twelve supplement cases and edition 02's longitudinal notes.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-019","number":19,"summary":"Batch 19 (7 Oct 2026) narrows the question to one sequence: a person reports a hazard; the institution turns to the reporter's mental fitness; a psychiatric referral, examination, threat, detention, diagnosis or employment restriction follows; the hazard report is addressed, sidelined or left open. It opens with *Petitt v. Delta* from the Department of Labor's own decisions, adds the nuclear-sector precedent *Diaz-Robainas v. Florida Power & Light*, maps the federal, military, nuclear, rail and California-healthcare rules that name psychiatric referral as a possible reprisal, and separates the NRC's chilled-work-environment record from psychiatric-specific retaliation.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-020","number":20,"summary":"Reconciliation with Compilation Edition 03; corrections applied while preserving earlier assertions.","document_id":"DOC-815c9747822d7c19","source_structure":"consolidated record; no separate original batch file supplied"},{"id":"BATCH-021","number":21,"summary":"Safety-relevant engineers: Diaz-Robainas, Patrickson, technical concerns, referral grounds, contrary evidence and search gaps.","document_id":"DOC-15b8efeaf6dfd366","source_structure":"standalone"},{"id":"BATCH-022","number":22,"summary":"Referral consequences, contaminated background records, DOL digest recovery and Patrickson appeal reconciliation.","document_id":"DOC-8f03cf5e29f26c05","source_structure":"standalone"}],"records":[{"id":"1966-CA-DILEMMA-REPORT","revisions":[{"id":"1966-CA-DILEMMA-REPORT","fields":{"Key":"1966-CA-DILEMMA-REPORT","Date":"Nov 1966","People / institutions":"Assembly Subcommittee on Mental Health Services (Lanterman chair; Petris; staff authors)","Mechanism":"Legislative study","Allegation":"Pre-LPS commitment relied on indeterminate confinement and stripped legal rights","Finding or outcome":"OFFICIAL FINDING; basis of AB 1220 / SB 677 (1967)","Open questions":"Full report text is in few libraries; obtain and quote the sections on abuse of process"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":156},"source_urls":[]}],"source_ids":[]},{"id":"1967-CA-LPS-ENACTED","revisions":[{"id":"1967-CA-LPS-ENACTED","fields":{"Key":"1967-CA-LPS-ENACTED","Date":"1967–1969","People / institutions":"Legislature; Gov. Reagan","Mechanism":"Statute (Stats. 1967, ch. 1667; 1968 chs. 1170, 1199, 1374; 1969 ch. 722)","Allegation":"—","Finding or outcome":"Ends indeterminate commitment; creates 72-hour / 14-day / conservatorship ladder; 1969 adds counsel on certification","Open questions":"Wikipedia dates \"full effect\" to 1972 — reconcile with Thorn's \"operative July 1, 1969\" (likely phased county implementation)"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":157},"source_urls":[]}],"source_ids":[]},{"id":"1969-CA-SD-GREEN","revisions":[{"id":"1969-CA-SD-GREEN","fields":{"Key":"1969-CA-SD-GREEN","Date":"19 Jul–4 Aug 1969","People / institutions":"San Diego private psychiatric hospital (Thorn petitioners); Defenders, Inc.; Superior Court","Mechanism":"5250","Allegation":"Hospital refused appointed counsel access to a certified patient who, it said, had not asked for a lawyer","Finding or outcome":"Patient discharged near the end of certification once a writ issued; Supreme Court upheld the court's standing order (Thorn, 1970)","Open questions":"Not retaliation — but a documented early instance of a facility controlling a detained person's access to counsel"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":158},"source_urls":[]}],"source_ids":[]},{"id":"1970-CA-THORN","revisions":[{"id":"1970-CA-THORN","fields":{"Key":"1970-CA-THORN","Date":"26 Jan 1970","People / institutions":"Cal. Supreme Court; Citizens Advisory Council amicus","Mechanism":"Judicial construction","Allegation":"—","Finding or outcome":"JUDICIAL FINDING: refusal of voluntary treatment is \"tantamount to a request for release\"; court flags \"role conflict\" in having the treating facility explain rights","Open questions":"Did counties adopt the suggested third-party rights advisement? Trace to §§ 5252.1, 5256 history"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":159},"source_urls":[]}],"source_ids":[]},{"id":"1971-CA-ELLSBERG-FIELDING","revisions":[{"id":"1971-CA-ELLSBERG-FIELDING","fields":{"Key":"1971-CA-ELLSBERG-FIELDING","Date":"3 Sep 1971","People / institutions":"White House Plumbers (Krogh, Liddy, Hunt, Cuban operatives); Dr. Lewis Fielding, Beverly Hills; Daniel Ellsberg","Mechanism":"Psychiatric records sought to discredit a whistleblower (no detention, no 5150)","Allegation":"Operation aimed to build a \"psychiatric profile\" to discredit Ellsberg","Finding or outcome":"ADMISSION (Krogh guilty plea); JUDICIAL FINDING (Ehrlichman convicted 1974, affirmed 1976; Liddy convicted); Ellsberg prosecution dismissed May 1973 for government misconduct","Open questions":"Strongest purpose-evidence in the California record, though the instrument was records, not confinement"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":160},"source_urls":[]}],"source_ids":[]},{"id":"1972-CA-MITCHELL","revisions":[{"id":"1972-CA-MITCHELL","fields":{"Key":"1972-CA-MITCHELL","Date":"Jun 1972","People / institutions":"Martha Mitchell; security guard Steve King; a physician; Newport Beach hotel","Mechanism":"Private physical restraint and forced sedation (not 5150)","Allegation":"Restrained and injected after phoning UPI's Helen Thomas about Watergate; her account publicly dismissed as drunkenness or delusion","Finding or outcome":"Later corroborated by Watergate record; no legal proceeding over the restraint located","Open questions":"LEAD: find contemporaneous UPI/press accounts and King's later statements; confirm no 5150 was invoked"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":161},"source_urls":[]}],"source_ids":[]},{"id":"1973-CA-ROSENHAN","revisions":[{"id":"1973-CA-ROSENHAN","fields":{"Key":"1973-CA-ROSENHAN","Date":"1973","People / institutions":"David Rosenhan, Stanford; 12 hospitals (locations partly in California)","Mechanism":"Pseudopatient admission","Allegation":"Hospitals cannot distinguish sane from insane; labels stick","Finding or outcome":"DISPUTED: Cahalan (2019) found Rosenhan's notes contradict the article and most pseudopatients cannot be verified","Open questions":"Treat as a caution about evidence quality, not as proof of institutional failure"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":162},"source_urls":[]}],"source_ids":[]},{"id":"1977-CA-DOE-GALLINOT","revisions":[{"id":"1977-CA-DOE-GALLINOT","fields":{"Key":"1977-CA-DOE-GALLINOT","Date":"1977–1981","People / institutions":"\"John Doe\"; LA County mental health director Gallinot; 9th Circuit","Mechanism":"5250","Allegation":"Fourteen-day certification without any hearing violated due process","Finding or outcome":"JUDICIAL FINDING (657 F.2d 1017): probable-cause hearing required; § 5256 certification review hearings follow","Open questions":"Open the opinion; confirm facts of the underlying detention"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":163},"source_urls":[]}],"source_ids":[]},{"id":"1979-CA-ROULET","revisions":[{"id":"1979-CA-ROULET","fields":{"Key":"1979-CA-ROULET","Date":"1979","People / institutions":"Cal. Supreme Court","Mechanism":"LPS-CONSERVATORSHIP","Allegation":"—","Finding or outcome":"JUDICIAL FINDING (23 Cal.3d 219): reasonable-doubt standard, unanimous jury","Open questions":"Later narrowing by Conservatorship of John L. (2010)? LEAD"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":164},"source_urls":[]}],"source_ids":[]},{"id":"1987-CA-RIESE","revisions":[{"id":"1987-CA-RIESE","fields":{"Key":"1987-CA-RIESE","Date":"1987","People / institutions":"Eleanor Riese; St. Mary's Hospital, San Francisco; California Alliance for the Mentally Ill (amicus)","Mechanism":"Forced antipsychotic medication under LPS","Allegation":"Involuntary patients medicated without consent or capacity determination","Finding or outcome":"JUDICIAL FINDING (209 Cal.App.3d 1303); codified Welf. & Inst. Code § 5332 (1991)","Open questions":"Riese capacity hearings are the main in-hold safeguard — Batch 2: how often are they requested and granted?"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":165},"source_urls":[]}],"source_ids":[]},{"id":"2008-CA-SPEARS","revisions":[{"id":"2008-CA-SPEARS","fields":{"Key":"2008-CA-SPEARS","Date":"3 & 31 Jan 2008; Feb 2008–12 Nov 2021","People / institutions":"Britney Spears; UCLA Medical Center; LA Superior Court (Judge Penny); conservators incl. Jamie Spears","Mechanism":"5150 (twice), then PROBATE-CONSERVATORSHIP (not LPS)","Allegation":"23 Jun 2021 testimony: forced lithium, IUD removal refused, work compelled; characterized by her as retaliation for refusing shows","Finding or outcome":"ALLEGATION; father's counsel disputed and asked the court to investigate; conservatorship terminated 2021 without findings on the allegations","Open questions":"Court investigator reports remain sealed? AB 1194 (2021) reforms traced to this case — verify"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":166},"source_urls":[]}],"source_ids":[]},{"id":"2016–2017-CA-JULIAN","revisions":[{"id":"2016–2017-CA-JULIAN","fields":{"Key":"2016–2017-CA-JULIAN","Date":"2017 (events earlier)","People / institutions":"Katia Julian, LAUSD middle-school teacher; school police; Mission Community Hospital; examining physician","Mechanism":"5150, overnight admission","Allegation":"No probable cause; detention followed a workplace dispute (officers were investigating an alleged assault on Julian)","Finding or outcome":"REJECTED on legal grounds (11 Cal.App.5th 360): no private right of action under LPS; § 5278 immunity; qualified immunity; hospital not a state actor","Open questions":"The appellate opinion never reaches whether the hold was retaliatory — a structural gap, not an exoneration"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":167},"source_urls":[]}],"source_ids":[]},{"id":"2020-CA-AUDIT-2019-119","revisions":[{"id":"2020-CA-AUDIT-2019-119","fields":{"Key":"2020-CA-AUDIT-2019-119","Date":"28 Jul 2020","People / institutions":"California State Auditor; LA, SF, Shasta counties","Mechanism":"Audit of 60 holds and 60 conservatorships","Allegation":"—","Finding or outcome":"OFFICIAL FINDING: criteria applied appropriately in all sampled cases; \\~7,400 LA County residents had 5+ holds in FY2015–16 to 2017–18, 9% enrolled in intensive care; DOJ data cover only danger-based holds","Open questions":"Sample was not selected to detect misuse; grave-disability holds unmeasured"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":168},"source_urls":[]}],"source_ids":[]},{"id":"2020-CA-ALAMEDA-DRC","revisions":[{"id":"2020-CA-ALAMEDA-DRC","fields":{"Key":"2020-CA-ALAMEDA-DRC","Date":"2020 (filed)","People / institutions":"Disability Rights California; Alameda County; John George Psychiatric Hospital","Mechanism":"5150 pattern","Allegation":"Repeated short-term holds without connection to care, falling mostly on Black residents; county hold rate >3x state average","Finding or outcome":"ALLEGATION; hospital counsel called the race allegations \"superfluous\"","Open questions":"LEAD: docket number, current status, any settlement terms"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":169},"source_urls":[]}],"source_ids":[]},{"id":"2023-CA-SB43","revisions":[{"id":"2023-CA-SB43","fields":{"Key":"2023-CA-SB43","Date":"2023 (effective 2024–2026)","People / institutions":"Legislature","Mechanism":"Statute","Allegation":"—","Finding or outcome":"Expands \"gravely disabled\" to severe substance use disorder and inability to provide for medical care or personal safety","Open questions":"SUPPORTED, text not opened in this batch; monitor for effect on hold volumes"},"section":"California case and incident register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":170},"source_urls":[]}],"source_ids":[]},{"id":"1960s–1980s-USSR-PUNITIVE","revisions":[{"id":"1960s–1980s-USSR-PUNITIVE","fields":{"Key":"1960s–1980s-USSR-PUNITIVE","Country / period":"USSR, c. 1960–1989","Mechanism":"Forensic diagnosis (Snezhnevsky's \"sluggish schizophrenia,\" with symptoms such as \"reform delusions\"), Serbsky Institute evaluations, special psychiatric hospitals; estimated one-third of political prisoners held psychiatrically","Documentation and status":"ADMISSION by the Soviet delegation at the 1989 WPA Athens congress; Bukovsky's 1971 documents; Bloch & Reddaway, *Psychiatric Terror* (1977/1984); [van Voren 2010](https://pmc.ncbi.nlm.nih.gov/articles/PMC2800147)","Similarity to California":"Elastic diagnostic categories; psychiatric labels discounting a speaker's later testimony","Difference from California":"State designed the mechanism; no independent courts, counsel, or habeas; confinement indefinite"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":178},"source_urls":["https://pmc.ncbi.nlm.nih.gov/articles/PMC2800147"]}],"source_ids":["SRC-b4ac994607ddc364"]},{"id":"1971-USSR-BUKOVSKY","revisions":[{"id":"1971-USSR-BUKOVSKY","fields":{"Key":"1971-USSR-BUKOVSKY","Country / period":"USSR, 1971","Mechanism":"Dissident smuggles six forensic files to the West; sentenced to 12 years","Documentation and status":"VERIFIED (secondary): [HRW 2002](https://www.hrw.org/reports/2002/china02/china0802-02.htm); [Psychiatric News](https://psychiatryonline.org/doi/10.1176/pn.45.22.psychnews_45_22_024)","Similarity to California":"Whistleblowing about psychiatric misuse itself punished","Difference from California":"Punishment by criminal sentence, not by psychiatry"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":179},"source_urls":["https://www.hrw.org/reports/2002/china02/china0802-02.htm","https://psychiatryonline.org/doi/10.1176/pn.45.22.psychnews_45_22_024"]}],"source_ids":["SRC-0cffd21051577023","SRC-1d36f4b38617176e"]},{"id":"1977-WPA-HAWAII","revisions":[{"id":"1977-WPA-HAWAII","fields":{"Key":"1977-WPA-HAWAII","Country / period":"WPA, Honolulu 1977; Vienna 1983; Athens 1989","Mechanism":"Professional-body sanction: Declaration of Hawaii; Soviet society resigns Jan 1983 ahead of expulsion; readmission conditioned on \"sincere co-operation\"","Documentation and status":"VERIFIED (secondary): [RCPsych Bulletin 1990](https://pb.rcpsych.org/content/14/3/129.full-text.pdf+html)","Similarity to California":"Model for professional oversight external to the state","Difference from California":"California has no equivalent external professional sanction mechanism for individual holds"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":180},"source_urls":["https://pb.rcpsych.org/content/14/3/129.full-text.pdf+html"]}],"source_ids":["SRC-da545c7d2b86fd54"]},{"id":"1980s–present-CHINA-ANKANG","revisions":[{"id":"1980s–present-CHINA-ANKANG","fields":{"Key":"1980s–present-CHINA-ANKANG","Country / period":"China, 1980s–present","Mechanism":"Police-run Ankang hospitals (about 20 as of 2011); petitioners, Falun Gong practitioners, and activists confined; since 2010s mostly in ordinary wards with police–hospital cooperation","Documentation and status":"VERIFIED: [HRW 2002 *Dangerous Minds*](https://www.hrw.org/reports/2002/china02/china0802-02.htm); [HRW 2013](https://www.hrw.org/news/2013/05/03/china-end-arbitrary-detention-mental-health-institutions); [Safeguard Defenders 2022](https://safeguarddefenders.com/sites/default/files/pdf/EXECUTIVE%20SUMMARY%20EN.pdf) (140+ sources, 2015–2021)","Similarity to California":"Confinement used against complainants and petitioners — the closest analogue to \"silencing a person who files grievances\"; NGO notes it \"acts as a deterrent\"","Difference from California":"Police run or direct the facilities; the 2013 law exempts Ankang hospitals; no effective court review"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":181},"source_urls":["https://www.hrw.org/reports/2002/china02/china0802-02.htm","https://www.hrw.org/news/2013/05/03/china-end-arbitrary-detention-mental-health-institutions","https://safeguarddefenders.com/sites/default/files/pdf/EXECUTIVE%20SUMMARY%20EN.pdf"]}],"source_ids":["SRC-0cffd21051577023","SRC-f159deacb656af64","SRC-a41473ad2e11581f"]},{"id":"1992–2005-CHINA-WANG-WANXING","revisions":[{"id":"1992–2005-CHINA-WANG-WANXING","fields":{"Key":"1992–2005-CHINA-WANG-WANXING","Country / period":"China","Mechanism":"Wang Wanxing held 13 years after a Tiananmen protest; on release to Germany, two psychiatrists found no disorder justifying admission","Documentation and status":"VERIFIED (secondary): [RFA 2011](https://www.rfa.org/english/news/china/mental-12282011101351.html)","Similarity to California":"Single-person long confinement with post-hoc independent evaluation contradicting the diagnosis","Difference from California":"Length and absence of review have no California parallel under LPS time limits"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":182},"source_urls":["https://www.rfa.org/english/news/china/mental-12282011101351.html"]}],"source_ids":["SRC-0c4cf7bfa9753260"]},{"id":"2013-CHINA-MHL","revisions":[{"id":"2013-CHINA-MHL","fields":{"Key":"2013-CHINA-MHL","Country / period":"China, 1 May 2013","Mechanism":"First national Mental Health Law; independent review provisions; Ankang largely exempt","Documentation and status":"VERIFIED: [Dui Hua 2012](https://duihua.org/?p=18355); [CHRD via Amnesty UK 2013](https://www.amnesty.org.uk/knowledge-hub/all-resources/chrb-six-months-after-mental-health-law-took-effect-involuntary-psychiatric/) documents petitioners confined within months of effect","Similarity to California":"Reform statute that leaves the enforcement channel intact — compare LPS immunity and no-private-right-of-action gaps","Difference from California":"Different scale and intent"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":183},"source_urls":["https://duihua.org/?p=18355","https://www.amnesty.org.uk/knowledge-hub/all-resources/chrb-six-months-after-mental-health-law-took-effect-involuntary-psychiatric/"]}],"source_ids":["SRC-d8ed9550a276d847","SRC-7bcd9363b6f70bd1"]},{"id":"1979-ECHR-WINTERWERP","revisions":[{"id":"1979-ECHR-WINTERWERP","fields":{"Key":"1979-ECHR-WINTERWERP","Country / period":"Council of Europe","Mechanism":"Winterwerp v. Netherlands sets three conditions for lawful detention of \"persons of unsound mind\": objective medical expertise, a disorder warranting confinement, and persistence of the disorder","Documentation and status":"SUPPORTED (standard citation: ECtHR 24 Oct 1979, App. 6301/73)","Similarity to California":"Comparable to Addington / O'Connor minimums","Difference from California":"Supranational court review of national practice; no US equivalent"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":184},"source_urls":[]}],"source_ids":[]},{"id":"2004-ECHR-HL-UK","revisions":[{"id":"2004-ECHR-HL-UK","fields":{"Key":"2004-ECHR-HL-UK","Country / period":"United Kingdom","Mechanism":"HL v. UK (Bournewood): informal detention of a compliant incapacitated patient violated Art. 5","Documentation and status":"SUPPORTED","Similarity to California":"Highlights \"voluntary\" admissions that are not voluntary — relevant to California's voluntary/involuntary boundary","Difference from California":"—"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":185},"source_urls":[]}],"source_ids":[]},{"id":"2006–2015-UN-CRPD","revisions":[{"id":"2006–2015-UN-CRPD","fields":{"Key":"2006–2015-UN-CRPD","Country / period":"UN","Mechanism":"Convention on the Rights of Persons with Disabilities, Art. 14; 2015 Committee guidelines treat deprivation of liberty on the basis of impairment as discriminatory","Documentation and status":"SUPPORTED","Similarity to California":"Frames all disability-based detention, including LPS, as rights-contrary","Difference from California":"US has signed but not ratified; no domestic effect"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":186},"source_urls":[]}],"source_ids":[]},{"id":"2007–2014-RUSSIA-RESURGENCE","revisions":[{"id":"2007–2014-RUSSIA-RESURGENCE","fields":{"Key":"2007–2014-RUSSIA-RESURGENCE","Country / period":"Russia","Mechanism":"Larisa Arap (2007, Murmansk); Mikhail Kosenko (Bolotnaya case, court-ordered treatment 2013, released 2014)","Documentation and status":"LEAD: verify dates and dispositions against primary reporting","Similarity to California":"Post-reform recurrence","Difference from California":"—"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":187},"source_urls":[]}],"source_ids":[]},{"id":"2001–2017-UZBEKISTAN-URLAEVA","revisions":[{"id":"2001–2017-UZBEKISTAN-URLAEVA","fields":{"Key":"2001–2017-UZBEKISTAN-URLAEVA","Country / period":"Uzbekistan","Mechanism":"Human-rights monitor Elena Urlaeva repeatedly confined in psychiatric clinics","Documentation and status":"LEAD: verify episode dates","Similarity to California":"Repeated short confinements timed to activism","Difference from California":"—"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":188},"source_urls":[]}],"source_ids":[]},{"id":"1900–1987-JAPAN","revisions":[{"id":"1900–1987-JAPAN","fields":{"Key":"1900–1987-JAPAN","Country / period":"Japan","Mechanism":"1900 custody law legalized home confinement (shitaku kanchi); 1984 Utsunomiya Hospital deaths; 1987 Mental Health Act reform","Documentation and status":"SUPPORTED","Similarity to California":"Family-initiated confinement as in Packard-era US","Difference from California":"—"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":189},"source_urls":[]}],"source_ids":[]},{"id":"2009–2016-US-MILITARY","revisions":[{"id":"2009–2016-US-MILITARY","fields":{"Key":"2009–2016-US-MILITARY","Country / period":"United States (federal)","Mechanism":"Personality/adjustment-disorder discharges after sexual-assault reports; 31,000+ personality-disorder discharges FY2001–2010; DoD IG (2016) finds 67% of such discharges of assault reporters lacked required documentation","Documentation and status":"VERIFIED: [HRW *Booted*](https://hrw.org/news/2016/05/19/us-raped-military-then-punished); DoD IG DODIG-2016-088","Similarity to California":"Diagnosis as a credibility and benefits penalty for complainants","Difference from California":"Federal, not state; label without confinement"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":190},"source_urls":["https://hrw.org/news/2016/05/19/us-raped-military-then-punished"]}],"source_ids":["SRC-ade16f9af70aaf96"]},{"id":"1978-US-FITNESS-FOR-DUTY","revisions":[{"id":"1978-US-FITNESS-FOR-DUTY","fields":{"Key":"1978-US-FITNESS-FOR-DUTY","Country / period":"United States (federal)","Mechanism":"Forced psychiatric fitness-for-duty exams of employees in conflict with managers; 1978 House subcommittee finding of retaliatory use; MSPB surveys 1992–2010","Documentation and status":"VERIFIED (secondary): [Federal Times/MSPB](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/)","Similarity to California":"Threat of evaluation as workplace deterrent, with survey evidence of chill","Difference from California":"Evaluation rather than detention; regulated by OPM rules"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":191},"source_urls":["https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/"]}],"source_ids":["SRC-13d7b10d8f10fc9f"]},{"id":"2009-US-NY-SCHOOLCRAFT","revisions":[{"id":"2009-US-NY-SCHOOLCRAFT","fields":{"Key":"2009-US-NY-SCHOOLCRAFT","Country / period":"New York","Mechanism":"Emergency admission of a police whistleblower; six-day hold; hospital note found no significant symptoms","Documentation and status":"SETTLEMENT (2015); Queens DA: no crime","Similarity to California":"Closest US analogue to a 5150 used at the moment of disclosure","Difference from California":"NY Mental Hygiene Law § 9.39, not LPS"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":192},"source_urls":[]},{"id":"2009-US-NY-SCHOOLCRAFT","fields":{"Key":"2009-US-NY-SCHOOLCRAFT","Jurisdiction / date":"New York, 2009–2015","People / institutions":"Adrian Schoolcraft; NYPD 81st Precinct; Deputy Chief Marino; Jamaica Hospital","Mechanism":"NY Mental Hygiene Law emergency admission","Allegation or event":"Hospitalized hours after reporting crime-stat manipulation; sergeant recorded saying \"I'm going to have him psyched\"","Finding or outcome":"SETTLEMENT (2015); DA: no crime; NYPD confirmed the manipulation","Label":"SETTLEMENT"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":215},"source_urls":[]},{"id":"2009-US-NY-SCHOOLCRAFT","fields":{"Key":"2009-US-NY-SCHOOLCRAFT","Speech act":"Internal-affairs complaint and quota recordings","Psychiatric act":"Forced removal to Jamaica Hospital psychiatric ward","Interval":"Hours","Who initiated":"NYPD superiors","Outcome label":"SETTLEMENT"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":463},"source_urls":[]}],"source_ids":[]},{"id":"2012-US-VA-RAUB","revisions":[{"id":"2012-US-VA-RAUB","fields":{"Key":"2012-US-VA-RAUB","Country / period":"Virginia","Mechanism":"Temporary detention order over political Facebook posts; circuit judge dismissed petition as lacking factual allegations","Documentation and status":"JUDICIAL FINDING (procedural); Raub's civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\]","Similarity to California":"Speech-triggered hold","Difference from California":"Virginia TDO procedure includes a special-justice hearing within days — a step LPS lacks at the 72-hour stage"},"section":"International comparison register","batch":1,"provenance":{"document_id":"DOC-815c9747822d7c19","line":193},"source_urls":[]},{"id":"2012-US-VA-RAUB","fields":{"Key":"2012-US-VA-RAUB","Jurisdiction / date":"Virginia, 2012","People / institutions":"Brandon Raub; Chesterfield police; FBI; John Randolph Medical Center; Salem VA facility","Mechanism":"Virginia temporary detention order","Allegation or event":"Detained over political and lyric posts; held 7 days","Finding or outcome":"JUDICIAL FINDING: petition \"devoid of any factual allegations\"; civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\]","Label":"VERIFIED (secondary)"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":216},"source_urls":[]}],"source_ids":[]},{"id":"1851-US-LA-CARTWRIGHT","revisions":[{"id":"1851-US-LA-CARTWRIGHT","fields":{"Key":"1851-US-LA-CARTWRIGHT","Jurisdiction / date":"Louisiana, 1851","People / institutions":"Samuel Cartwright; Louisiana Medical Association","Mechanism":"Diagnostic category (drapetomania)","Allegation or event":"Flight from slavery framed as disease","Finding or outcome":"Discredited; cited as the origin case for race-based pathologizing","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":201},"source_urls":[]}],"source_ids":[]},{"id":"1860-US-IL-PACKARD","revisions":[{"id":"1860-US-IL-PACKARD","fields":{"Key":"1860-US-IL-PACKARD","Jurisdiction / date":"Illinois, 1860–1867","People / institutions":"Elizabeth Packard; Theophilus Packard; Jacksonville State Hospital","Mechanism":"Family-initiated commitment under 1851 statute exempting married women from the evidence requirement","Allegation or event":"Committed for religious dissent from her husband's views","Finding or outcome":"JUDICIAL FINDING (1864 jury: sane); statutory reform 1867","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":202},"source_urls":[]}],"source_ids":[]},{"id":"1887-US-NY-BLY","revisions":[{"id":"1887-US-NY-BLY","fields":{"Key":"1887-US-NY-BLY","Jurisdiction / date":"New York, 1887","People / institutions":"Nellie Bly; Blackwell's Island; New York World","Mechanism":"Admission on feigned symptoms","Allegation or event":"Minimal evidence sufficed for commitment; abuse inside","Finding or outcome":"Grand jury inquiry; appropriations increased","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":203},"source_urls":[]}],"source_ids":[]},{"id":"1945-US-DC-POUND","revisions":[{"id":"1945-US-DC-POUND","fields":{"Key":"1945-US-DC-POUND","Jurisdiction / date":"D.C., 1945–1958","People / institutions":"Ezra Pound; St. Elizabeths; Dr. Winfred Overholser","Mechanism":"COMPETENCY-EXAM","Allegation or event":"Found unfit for treason trial","Finding or outcome":"Indictment dismissed 1958; genuineness of the finding contested","Label":"DISPUTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":204},"source_urls":[]}],"source_ids":[]},{"id":"1956-US-AK-ENABLING-ACT","revisions":[{"id":"1956-US-AK-ENABLING-ACT","fields":{"Key":"1956-US-AK-ENABLING-ACT","Jurisdiction / date":"Alaska, 1956","People / institutions":"Congress; Alaska Mental Health Enabling Act; opponents alleging a \"Siberia\" plan","Mechanism":"Legislation","Allegation or event":"Campaign claimed the Act would allow mass psychiatric detention of political enemies","Finding or outcome":"Act passed; the panic is itself evidence of public fear of psychiatric detention as a political tool","Label":"LEAD"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":205},"source_urls":[]},{"id":"1956-US-AK-ENABLING-ACT","fields":{"Key":"1956-US-AK-ENABLING-ACT","Jurisdiction / date":"Alaska / Congress, 1956","Mechanism":"Legislation (P.L. 84-830)","What is documented":"Opponents' \"Siberia bill\" campaign alleged a plan for political detention; the panic shows public fear of psychiatric detention as a tool a decade before LPS","Finding or status":"Standard account","Limits":"Not opened this batch","Label":"SUPPORTED"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":286},"source_urls":[]}],"source_ids":[]},{"id":"1957-US-FL-DONALDSON","revisions":[{"id":"1957-US-FL-DONALDSON","fields":{"Key":"1957-US-FL-DONALDSON","Jurisdiction / date":"Florida, 1957–1975","People / institutions":"Kenneth Donaldson; Florida State Hospital, Chattahoochee; Dr. O'Connor","Mechanism":"LONG-COMMITMENT (father's petition)","Allegation or event":"Held \\~15 years without treatment though non-dangerous","Finding or outcome":"JUDICIAL FINDING: [O'Connor v. Donaldson (1975)](https://supreme.justia.com/cases/federal/us/422/563/)","Label":"VERIFIED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":206},"source_urls":["https://supreme.justia.com/cases/federal/us/422/563/"]}],"source_ids":["SRC-87490156fb2b13fd"]},{"id":"1964-US-GOLDWATER","revisions":[{"id":"1964-US-GOLDWATER","fields":{"Key":"1964-US-GOLDWATER","Jurisdiction / date":"US national, 1964–1973","People / institutions":"*Fact* magazine; 1,189 psychiatrists; APA","Mechanism":"Diagnostic discrediting without examination","Allegation or event":"Candidate declared psychologically unfit by polled psychiatrists","Finding or outcome":"Libel verdict for Goldwater (1969); APA \"Goldwater rule\" 1973","Label":"LEAD (verify verdict and rule text)"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":207},"source_urls":[]},{"id":"1964-US-GOLDWATER","fields":{"Key":"1964-US-GOLDWATER","Jurisdiction / date":"US national, 1964–1973","Mechanism":"Diagnostic discrediting","What is documented":"*Fact* polled psychiatrists; 1,189 declared Goldwater unfit; libel verdict for Goldwater affirmed 1969; APA adopts the \"Goldwater rule\" 1973","Finding or status":"Standard account","Limits":"Not opened this batch","Label":"SUPPORTED"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":285},"source_urls":[]}],"source_ids":[]},{"id":"1968-US-MI-PROTEST-PSYCHOSIS","revisions":[{"id":"1968-US-MI-PROTEST-PSYCHOSIS","fields":{"Key":"1968-US-MI-PROTEST-PSYCHOSIS","Jurisdiction / date":"Michigan, 1960s–1970s","People / institutions":"Ionia State Hospital; Bromberg & Simon (1968)","Mechanism":"Diagnostic category","Allegation or event":"Schizophrenia disproportionately diagnosed in Black men with civil-rights language in charts","Finding or outcome":"Archival finding (Metzl 2009)","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":208},"source_urls":[]}],"source_ids":[]},{"id":"1972-US-WI-LESSARD","revisions":[{"id":"1972-US-WI-LESSARD","fields":{"Key":"1972-US-WI-LESSARD","Jurisdiction / date":"Wisconsin, 1972","People / institutions":"Alberta Lessard; Milwaukee County","Mechanism":"Civil commitment","Allegation or event":"Commitment without notice, counsel, or hearing","Finding or outcome":"JUDICIAL FINDING: due-process minimums (349 F. Supp. 1078)","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":209},"source_urls":[]}],"source_ids":[]},{"id":"1972-US-AL-WYATT","revisions":[{"id":"1972-US-AL-WYATT","fields":{"Key":"1972-US-AL-WYATT","Jurisdiction / date":"Alabama, 1972","People / institutions":"Bryce Hospital patients","Mechanism":"LONG-COMMITMENT","Allegation or event":"No treatment for the committed","Finding or outcome":"JUDICIAL FINDING: right to treatment (Wyatt v. Stickney)","Label":"LEAD"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":210},"source_urls":[]}],"source_ids":[]},{"id":"1978-US-FED-FFD","revisions":[{"id":"1978-US-FED-FFD","fields":{"Key":"1978-US-FED-FFD","Jurisdiction / date":"US federal, 1978–2010","People / institutions":"USPHS; Donald Soeken; House Post Office and Civil Service subcommittee; OPM; MSPB","Mechanism":"FITNESS-FOR-DUTY","Allegation or event":"Exams ordered after personality conflicts and whistleblowing","Finding or outcome":"OFFICIAL FINDING (1978 report quoted in [Federal Times/MSPB](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/)); CHILL-RESEARCH (MSPB 1.6%→6.1%)","Label":"VERIFIED (secondary)"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":211},"source_urls":["https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/"]}],"source_ids":["SRC-13d7b10d8f10fc9f"]},{"id":"1979-US-TX-ADDINGTON","revisions":[{"id":"1979-US-TX-ADDINGTON","fields":{"Key":"1979-US-TX-ADDINGTON","Jurisdiction / date":"Texas, 1979","People / institutions":"Frank Addington","Mechanism":"Civil commitment","Allegation or event":"Preponderance standard insufficient","Finding or outcome":"JUDICIAL FINDING: clear and convincing ([441 U.S. 418](https://supreme.justia.com/cases/federal/us/441/418/))","Label":"VERIFIED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":212},"source_urls":["https://supreme.justia.com/cases/federal/us/441/418/"]}],"source_ids":["SRC-443f1aa3ffbe5b54"]},{"id":"1980-US-NE-VITEK","revisions":[{"id":"1980-US-NE-VITEK","fields":{"Key":"1980-US-NE-VITEK","Jurisdiction / date":"Nebraska, 1980","People / institutions":"Prisoner Larry Jones","Mechanism":"Prison-to-hospital transfer","Allegation or event":"Transfer without hearing","Finding or outcome":"JUDICIAL FINDING: hearing required (445 U.S. 480)","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":213},"source_urls":[]}],"source_ids":[]},{"id":"1990-US-WA-HARPER","revisions":[{"id":"1990-US-WA-HARPER","fields":{"Key":"1990-US-WA-HARPER","Jurisdiction / date":"Washington, 1990","People / institutions":"Prisoner Walter Harper","Mechanism":"Forced medication in prison","Allegation or event":"Medication without judicial hearing","Finding or outcome":"JUDICIAL FINDING: administrative review suffices (494 U.S. 210) — a limit on safeguards","Label":"SUPPORTED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":214},"source_urls":[]}],"source_ids":[]},{"id":"2015-US-FL-BAKER-ACT-CHILDREN","revisions":[{"id":"2015-US-FL-BAKER-ACT-CHILDREN","fields":{"Key":"2015-US-FL-BAKER-ACT-CHILDREN","Jurisdiction / date":"Florida, FY2015/16–FY2020/21","People / institutions":"USF Baker Act Reporting Center; school districts; SPLC v. Palm Beach County schools (2021)","Mechanism":"Florida Mental Health Act (Baker Act) involuntary examination","Allegation or event":"194,354 exams FY15/16; 205,781 FY17/18 incl. 36,078 children; 38,000+ children FY20/21 (+77% in a decade); most child exams initiated at school or by police","Finding or outcome":"OFFICIAL DATA ([DCF/USF report](https://myflfamilies.com/document/21586); [WPTV](https://www.wptv.com/news/local-news/investigations/baker-act-exams-among-florida-children-reach-historic-new-high)); lawsuit ALLEGATION","Label":"VERIFIED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":217},"source_urls":["https://myflfamilies.com/document/21586","https://www.wptv.com/news/local-news/investigations/baker-act-exams-among-florida-children-reach-historic-new-high"]}],"source_ids":["SRC-f0f9b77536f09635","SRC-9e33bbcf4f18872f"]},{"id":"2016-US-MIL-BOOTED","revisions":[{"id":"2016-US-MIL-BOOTED","fields":{"Key":"2016-US-MIL-BOOTED","Jurisdiction / date":"US military, 2001–2016","People / institutions":"HRW; Protect Our Defenders; DoD IG","Mechanism":"Personality/adjustment-disorder discharge","Allegation or event":"Survivors discharged after reporting assault; benefits lost","Finding or outcome":"OFFICIAL FINDING (IG: 67% lacked documentation); military contested framing","Label":"VERIFIED"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":218},"source_urls":[]}],"source_ids":[]},{"id":"2022-US-MA-SHEA","revisions":[{"id":"2022-US-MA-SHEA","fields":{"Key":"2022-US-MA-SHEA","Jurisdiction / date":"Massachusetts, 2012–2018 cohort","People / institutions":"4,393 inpatients","Mechanism":"Involuntary admission and court commitment petitions","Allegation or event":"Black patients aOR 1.57 for involuntary admission","Finding or outcome":"Peer-reviewed finding ([Psychiatric Services 2022](https://psychiatryonline.org/doi/abs/10.1176/appi.ps.202100342))","Label":"VERIFIED (abstract)"},"section":"United States national and state register","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":219},"source_urls":["https://psychiatryonline.org/doi/abs/10.1176/appi.ps.202100342"]}],"source_ids":["SRC-c97a4172b05d4b93"]},{"id":"2023-UK-MHA-ETHNICITY","revisions":[{"id":"2023-UK-MHA-ETHNICITY","fields":{"Key":"2023-UK-MHA-ETHNICITY","Country / period":"England, 2022/23–2024/25","Mechanism":"Detention under Mental Health Act 1983; police holding powers; Community Treatment Orders","What is documented":"Black people detained at 228 per 100,000 vs 64 for white people (year to March 2023), 3.5x; 3.8x in 2024/25; CTOs 7x; \\~52,500 detentions in 2023/24; those in the most deprived decile 3.7x more likely","Finding or status":"OFFICIAL DATA ([gov.uk Ethnicity facts and figures](https://www.ethnicity-facts-figures.service.gov.uk/health/mental-health/detentions-under-the-mental-health-act/latest/); [Mental Health Bill 2025 fact sheet](https://www.gov.uk/government/publications/mental-health-bill-2025-fact-sheet/mental-health-bill-2025-fact-sheet); [Parliament deposited evidence summary 2025](https://data.parliament.uk/DepositedPapers/Files/DEP2025-0227/Evidence_summary_drivers_of_racial_disparities-Mental_Health_Act.pdf))","Contrary evidence / limits":"Disparity, not retaliation; NHS says data undercount; drivers contested (access, deprivation, bias)","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":229},"source_urls":["https://www.ethnicity-facts-figures.service.gov.uk/health/mental-health/detentions-under-the-mental-health-act/latest/","https://www.gov.uk/government/publications/mental-health-bill-2025-fact-sheet/mental-health-bill-2025-fact-sheet","https://data.parliament.uk/DepositedPapers/Files/DEP2025-0227/Evidence_summary_drivers_of_racial_disparities-Mental_Health_Act.pdf"]}],"source_ids":["SRC-f889cae2b4e13fc3","SRC-fdbed2aaac378f5f","SRC-5b1bdd1af322a0d3"]},{"id":"2018-UK-WESSELY","revisions":[{"id":"2018-UK-WESSELY","fields":{"Key":"2018-UK-WESSELY","Country / period":"England, 2018–2025","Mechanism":"Independent Review of the MHA; Mental Health Bill 2025","What is documented":"Detentions rose by over a third 2006–2016; reforms aim to cut detention and disproportionality","Finding or status":"OFFICIAL (fact sheet above)","Contrary evidence / limits":"Outcome of the Bill not yet measurable","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":230},"source_urls":[]}],"source_ids":[]},{"id":"1938-ES-VALLEJO-NAGERA","revisions":[{"id":"1938-ES-VALLEJO-NAGERA","fields":{"Key":"1938-ES-VALLEJO-NAGERA","Country / period":"Spain, 1938–39 and after","Mechanism":"Military psychiatric studies of Republican prisoners (Vallejo-Nágera, \"Psiquismo del fanatismo marxista\")","What is documented":"Political opposition theorized as psychobiological inferiority; women prisoners of Málaga studied; linked to removal of children","Finding or status":"Scholarly consensus (Vinyes, Bandrés & Llavona); Spanish-language sources to be opened","Contrary evidence / limits":"Not detention by diagnosis; diagnosis legitimizing repression already under way","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":231},"source_urls":[]},{"id":"1938-ES-VALLEJO-NAGERA","fields":{"Key":"1938-ES-VALLEJO-NAGERA","Country / period":"Spain, Aug 1938–Oct 1939","Mechanism":"Military psychiatric research on prisoners","What is documented":"Franco's telegram of 23 Aug 1938 authorized Vallejo-Nágera's Gabinete de Investigaciones Psicológicas; studies on International Brigade prisoners and 50 Republican women in Málaga prison, published in *Revista Española de Medicina y Cirugía de Guerra* (1938–39), framed Marxism as biopsychic inferiority and women's activism as cruelty; theory invoked for the separation of children of \"red\" mothers (Garzón's 2008 auto estimated \\~30,000)","Finding or status":"Scholarly and official-memory sources ([Junta de Andalucía, Lugar de Memoria: Cárcel de Mujeres de Málaga](https://www.juntadeandalucia.es/organismos/culturaydeporte/areas/cultura/memoria-democratica/lugares-memoria-democratica/paginas/antigua-carcel-mujeres.html); [Público](https://www.publico.es/politica/franco-busca-gen-rojo-inferioridad.amp.html); [eHumanista/IVITRA 23](https://ehumanista.ucsb.edu/sites/default/files/sitefiles/ivitra/volume23/1.3.%20Mininni.pdf); [Univ. de Jaén](https://revistaselectronicas.ujaen.es/index.php/rae/article/download/8839/8627/58619))","Limits":"Diagnosis legitimized repression already under way; no confinement by diagnosis","Label":"VERIFIED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":300},"source_urls":["https://www.juntadeandalucia.es/organismos/culturaydeporte/areas/cultura/memoria-democratica/lugares-memoria-democratica/paginas/antigua-carcel-mujeres.html","https://www.publico.es/politica/franco-busca-gen-rojo-inferioridad.amp.html","https://ehumanista.ucsb.edu/sites/default/files/sitefiles/ivitra/volume23/1.3.%20Mininni.pdf","https://revistaselectronicas.ujaen.es/index.php/rae/article/download/8839/8627/58619"]}],"source_ids":["SRC-27ac6c3df1eecc07","SRC-772387c8547c1fd6","SRC-6af8bea6a7f8650c","SRC-6ba7e09db0ccf787"]},{"id":"1913-FR-CLAUDEL","revisions":[{"id":"1913-FR-CLAUDEL","fields":{"Key":"1913-FR-CLAUDEL","Country / period":"France, 1913–1943","Mechanism":"Family-initiated commitment (loi de 1838)","What is documented":"Camille Claudel confined 30 years at her family's request despite physicians' notes supporting release","Finding or status":"Archival record (Montdevergues)","Contrary evidence / limits":"Her diagnosis is itself contested; not a political case","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":232},"source_urls":[]},{"id":"1913-FR-CLAUDEL","fields":{"Key":"1913-FR-CLAUDEL","Jurisdiction / date":"France, 10 Mar 1913 – 19 Oct 1943","Mechanism":"*Placement volontaire* under the loi du 30 juin 1838 — family-requested admission on one physician's certificate; the committed person acquired the legal status of a minor","What is documented":"Dr Michaux signed the certificate on 7 Mar 1913, five days after her father's death; her mother requested the placement and her brother Paul initiated it; admitted to Ville-Évrard, transferred to Montdevergues in Sept 1914; the 1914 admission certificate recorded \"systematic persecution delusion\"; biographers and psychiatrist Michel Deveaux record that doctors considered her releasable in the 1920s and that the family refused; the press at the time questioned the severity of the measure and the 1838 law; visitors described her as lucid; she stopped sculpting and died in the asylum","Finding or status":"Museum chronology and standard biographies ([Musée Camille Claudel, \"1909–1943: period of confinement\"](https://museecamilleclaudel.fr/en/collections/camille-claudel-biography/1909-1943-period-confinement); [The Conversation, comparing the Spears conservatorship](https://theconversation.edu.au/britney-spearss-conservatorship-alludes-to-an-older-story-of-controlling-women-artists-164918))","Limits":"She had shown symptoms since at least 1905–1911; the dispute is over the 30-year duration against medical advice, not the initial admission; motives attributed to the family (protecting Paul's career, inheritance) are inference","Label":"DISPUTED on motive; VERIFIED on duration and family control"},"section":"Worldwide register by region (Batch 2)","batch":9,"provenance":{"document_id":"DOC-815c9747822d7c19","line":361},"source_urls":["https://museecamilleclaudel.fr/en/collections/camille-claudel-biography/1909-1943-period-confinement","https://theconversation.edu.au/britney-spearss-conservatorship-alludes-to-an-older-story-of-controlling-women-artists-164918"]}],"source_ids":["SRC-a90964ce410851aa","SRC-4005b35e67574b8a"]},{"id":"1978-IT-BASAGLIA","revisions":[{"id":"1978-IT-BASAGLIA","fields":{"Key":"1978-IT-BASAGLIA","Country / period":"Italy, 1978","Mechanism":"Law 180 abolishing asylum admission","What is documented":"Reform model; Trieste","Finding or status":"Statute","Contrary evidence / limits":"Implementation uneven by region","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":233},"source_urls":[]}],"source_ids":[]},{"id":"1939-DE-T4","revisions":[{"id":"1939-DE-T4","fields":{"Key":"1939-DE-T4","Country / period":"Germany, 1939–41","Mechanism":"State killing of psychiatric patients (\\~70,000)","What is documented":"The limit case of psychiatry as state instrument; not silencing of speakers","Finding or status":"Nuremberg Doctors' Trial; German federal acknowledgment","Contrary evidence / limits":"Outside the mission's core question but anchors the spectrum","Label":"SUPPORTED"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":234},"source_urls":[]}],"source_ids":[]},{"id":"1998-DDR-SUESS","revisions":[{"id":"1998-DDR-SUESS","fields":{"Key":"1998-DDR-SUESS","Country / period":"East Germany, 1949–89","Mechanism":"Stasi use of psychiatry","What is documented":"Süß (1998) found no systematic Soviet-style abuse but individual cases and psychiatrists as informers","Finding or status":"Scholarly study on Stasi files","Contrary evidence / limits":"Contrary to the common assumption that every bloc state copied the USSR","Label":"DISPUTED / LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":235},"source_urls":[]},{"id":"1998-DDR-SUESS","fields":{"Key":"1998-DDR-SUESS","Country / period":"East Germany, 1949–1989","Mechanism":"Stasi and psychiatry","What is documented":"Süß's 773-page study for the Stasi Records Agency found: psychiatrists serving as informers betrayed patient confidences; psychiatric patients were temporarily admitted around state holidays as potential \"disruptors\"; several cases of psychiatric misuse to discipline inconvenient people were proven; but no systematic Soviet- or Romanian-style instrument","Finding or status":"Official-archive study ([Bundesarchiv publication page](https://www.bundesarchiv.de/publikationen/publikation/politisch-missbraucht)); Saxony's Psychiatric Abuse Commission final report; a Leipzig researcher's 1972 Waldheim confinement ruled \"not justified\" in a 1992 rehabilitation ([Ärzteblatt](https://www.aerzteblatt.de/archiv/67363/Die-waldheim-story-Psychiatriemissbrauch-selbst-erlebt))","Limits":"Critics (Eckstein; FU Berlin journal) argue Süß understated; Süß replied that corrective mechanisms inside GDR psychiatry worked in the cases examined","Label":"DISPUTED (both sides opened)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":301},"source_urls":["https://www.bundesarchiv.de/publikationen/publikation/politisch-missbraucht","https://www.aerzteblatt.de/archiv/67363/Die-waldheim-story-Psychiatriemissbrauch-selbst-erlebt"]}],"source_ids":["SRC-b5c990e4ae2b97a1","SRC-e756b0c4c2001799"]},{"id":"2021-RU-GABYSHEV","revisions":[{"id":"2021-RU-GABYSHEV","fields":{"Key":"2021-RU-GABYSHEV","Country / period":"Russia (Yakutia), 2019–2021 onward","Mechanism":"Court-ordered compulsory treatment after forensic finding of \"insanity\" (невменяемость)","What is documented":"Shaman Alexander Gabyshev, who marched toward Moscow to \"exorcise\" Putin, forcibly sent to a dispensary Jan 2021; Yakutsk court ordered compulsory treatment Jul 2021; Yakutia Supreme Court approved transfer 23 Sep 2021; held in Novosibirsk from 25 Sep 2021; still confined as of 2023","Finding or status":"NGO finding: [Amnesty Urgent Action, 7 Oct 2021 (Russian)](https://eurasia.amnesty.org/wp-content/uploads/2021/10/shaman-podvergnut-karatelnoj-psihiatrii.pdf); [Novaya Gazeta Europe, 16 Aug 2023 (Russian)](https://novayagazeta.eu/articles/2023/08/16/osobo-buinye)","Contrary evidence / limits":"Treatment is court-ordered under criminal procedure, so formally lawful; the Independent Psychiatric Association of Russia disputes the diagnosis","Label":"VERIFIED (secondary, local-language)"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":241},"source_urls":["https://eurasia.amnesty.org/wp-content/uploads/2021/10/shaman-podvergnut-karatelnoj-psihiatrii.pdf","https://novayagazeta.eu/articles/2023/08/16/osobo-buinye"]}],"source_ids":["SRC-e80716fd82f762c5","SRC-843678ada0dc4730"]},{"id":"2023-RU-PETROVA","revisions":[{"id":"2023-RU-PETROVA","fields":{"Key":"2023-RU-PETROVA","Country / period":"Russia (St Petersburg), May 2022–Dec 2023","Mechanism":"Pre-trial transfer to psychiatric hospital (Oct 2023); compulsory treatment ordered 25 Dec 2023 for \"army fakes\" (Art. 207.3)","What is documented":"Forensic exam found she \"could not understand her actions\" when posting anti-war videos; lawyer reports she was stripped before male staff, restrained, injected with unknown drugs and could barely speak for days; minimum six months, extendable indefinitely","Finding or status":"Court order; survivor account via counsel: [Meduza, 25 Dec 2023 (Russian)](https://meduza.io/news/2023/12/25/sud-v-peterburge-napravil-viktoriyu-petrovu-na-prinuditelnoe-lechenie-v-psihiatricheskiy-statsionar-ee-obvinyali-v-feykah-ob-armii-iz-za-posta-o-shizofrenii-putina); [Moscow Times (Russian)](https://ru.themoscowtimes.com/2023/12/25/obvinyaemuyu-v-voennih-feikah-zhitelnitsu-peterburga-otpravili-na-prinuditelnoe-lechenie-v-psihbolnitsu-a117101)","Contrary evidence / limits":"Prosecution had sought prison; court chose \"mildest\" hospital regime; the hospital account is the defence's","Label":"VERIFIED (secondary, local-language)"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":242},"source_urls":["https://meduza.io/news/2023/12/25/sud-v-peterburge-napravil-viktoriyu-petrovu-na-prinuditelnoe-lechenie-v-psihiatricheskiy-statsionar-ee-obvinyali-v-feykah-ob-armii-iz-za-posta-o-shizofrenii-putina","https://ru.themoscowtimes.com/2023/12/25/obvinyaemuyu-v-voennih-feikah-zhitelnitsu-peterburga-otpravili-na-prinuditelnoe-lechenie-v-psihbolnitsu-a117101"]}],"source_ids":["SRC-d2002938b3071402","SRC-add679c2860a0e7f"]},{"id":"2022-RU-ONOSHKIN-NEPEIN-KUZMINA","revisions":[{"id":"2022-RU-ONOSHKIN-NEPEIN-KUZMINA","fields":{"Key":"2022-RU-ONOSHKIN-NEPEIN-KUZMINA","Country / period":"Russia, 2022–2023","Mechanism":"Compulsory in-patient or out-patient treatment in political cases","What is documented":"Aleksei Onoshkin (Nizhny Novgorod, anti-war posts, Jun 2022 and Oct 2023); Oleg Nepein (Saratov municipal deputy, Sep–Oct 2023); Kuzmina (Moscow, 4 Aug 2023); Moscow Times counts at least seven cases","Finding or status":"Local-language reporting (Meduza podcast 28 Nov 2023; Novaya Europe; Moscow Times)","Contrary evidence / limits":"Each is a criminal-procedure forensic outcome; no official admission of political purpose","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":243},"source_urls":[]}],"source_ids":[]},{"id":"2004-TM-DURDYKULIEV","revisions":[{"id":"2004-TM-DURDYKULIEV","fields":{"Key":"2004-TM-DURDYKULIEV","Country / period":"Turkmenistan, 2004","Mechanism":"Psychiatric confinement of a would-be protest organizer","What is documented":"Gurbandurdy Durdykuliev held after requesting permission for a demonstration","Finding or status":"HRW/Amnesty reporting","Contrary evidence / limits":"—","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":244},"source_urls":[]}],"source_ids":[]},{"id":"2001-UZ-URLAEVA","revisions":[{"id":"2001-UZ-URLAEVA","fields":{"Key":"2001-UZ-URLAEVA","Country / period":"Uzbekistan, 2001–2017","Mechanism":"Repeated compulsory psychiatric confinement","What is documented":"Human-rights monitor Elena Urlaeva","Finding or status":"HRW reporting","Contrary evidence / limits":"—","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":245},"source_urls":[]}],"source_ids":[]},{"id":"1972-NZ-LAKE-ALICE","revisions":[{"id":"1972-NZ-LAKE-ALICE","fields":{"Key":"1972-NZ-LAKE-ALICE","Country / period":"New Zealand, 1972–1978","Mechanism":"Child and adolescent psychiatric unit; unmodified ECT and paraldehyde used as punishment; seclusion","What is documented":"362–450 children; many admitted from welfare care without psychiatric diagnosis; shocks for running away or complaining; \\~41% of welfare-residence admissions were Māori; complaints to agencies and professional bodies went uninvestigated for decades","Finding or status":"OFFICIAL FINDING: Royal Commission *Beautiful Children* (Dec 2022) finds torture and systemic failure to respond to complaints ([abuseincare.org.nz](https://abuseincare.org.nz/our-progress/news/children-tortured-at-lake-alice-and-failed-by-the-state-royal-commission); [timeline](https://abuseincare.org.nz/reports/inquiry-into-the-lake-alice-child-and-adolescent-unit/executive-summary/timeline)); UN CAT found inadequate investigation (Zentveld, Jan 2020; Richards, Jun 2022); government formally acknowledged torture 2024; one nurse charged Dec 2021, prosecution stayed; Dr Leeks never tried ([Newsroom](https://www.newsroom.co.nz/courts-stay-ends-quest-for-justice); [PMC review](https://pmc.ncbi.nlm.nih.gov/articles/PMC10466991/))","Contrary evidence / limits":"Mechanism is punishment and silencing of children's complaints, not political dissent; 1977 Ombudsman and Medical Council processes produced no sanction","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":251},"source_urls":["https://abuseincare.org.nz/our-progress/news/children-tortured-at-lake-alice-and-failed-by-the-state-royal-commission","https://abuseincare.org.nz/reports/inquiry-into-the-lake-alice-child-and-adolescent-unit/executive-summary/timeline","https://www.newsroom.co.nz/courts-stay-ends-quest-for-justice","https://pmc.ncbi.nlm.nih.gov/articles/PMC10466991/"]}],"source_ids":["SRC-85ca94d5d896c6eb","SRC-6551b5326f1379fb","SRC-2e69d2b07f9b2ab3","SRC-54b11cee88c1d45c"]},{"id":"1963-AU-CHELMSFORD","revisions":[{"id":"1963-AU-CHELMSFORD","fields":{"Key":"1963-AU-CHELMSFORD","Country / period":"Australia (NSW), 1963–1979","Mechanism":"\"Deep sleep therapy\" at a private hospital; 24+ deaths","What is documented":"Royal Commission (Slattery, 1990)","Finding or status":"OFFICIAL FINDING","Contrary evidence / limits":"Malpractice more than silencing; included in the spectrum","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":252},"source_urls":[]},{"id":"1963-AU-CHELMSFORD","fields":{"Key":"1963-AU-CHELMSFORD","Country / period":"Australia (NSW), 1963–1979; Royal Commission 1988–1990","Mechanism":"Private psychiatric hospital; barbiturate \"deep sleep therapy\" with ECT; false death certificates","What is documented":"24 deaths from the treatment (other counts reach 85 including later suicides); only four deaths reached a coroner; complaints from patients and families produced coronial findings of no case to answer; Bailey himself was later secretly given the treatment by his partner","Finding or status":"OFFICIAL FINDING: Slattery Royal Commission, 12 volumes, reports 17 and 21 Dec 1990 — irresponsible experimentation, fraud, gross negligence; treatment banned; coronial and medical-complaints law reformed ([Dictionary of Sydney](https://dictionaryofsydney.org/index.php/node/66876); [NSW State Archives description](https://researchdata.edu.au/agy-6764-royal-royal-commission/2754627); [Wellcome Collection film record](https://content.www.wellcomecollection.org/works/pn7pqjv7))","Contrary evidence / limits":"Malpractice rather than political silencing; but a second documented case (with Lake Alice) of complaint channels failing for over a decade","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":4,"provenance":{"document_id":"DOC-815c9747822d7c19","line":316},"source_urls":["https://dictionaryofsydney.org/index.php/node/66876","https://researchdata.edu.au/agy-6764-royal-royal-commission/2754627","https://content.www.wellcomecollection.org/works/pn7pqjv7"]}],"source_ids":["SRC-7a21afc872023835","SRC-05b961ea27feab85","SRC-cbcb4f3b2139ac25"]},{"id":"1935-CA-QC-DUPLESSIS","revisions":[{"id":"1935-CA-QC-DUPLESSIS","fields":{"Key":"1935-CA-QC-DUPLESSIS","Country / period":"Quebec, 1935–1964","Mechanism":"False diagnosis of children as mentally deficient to convert orphanages into subsidized psychiatric hospitals; thousands confined","What is documented":"A 1960s commission found about one-third of patients held under false diagnoses; labels remained on records; Quebec apologies 1999 and 2001; compensation $10,000 + $1,000 per year confined (2001), $26 million (2006), $15,000 each to 1,270 more (2007); Church declined to apologize","Finding or status":"OFFICIAL (apology and compensation); Ombudsman Jacoby's 1999 criticism ([Canadian Encyclopedia](https://thecanadianencyclopedia.ca/en/article/duplessis-orphans); [historyofrights.ca](https://historyofrights.ca/encyclopaedia/main-events/duplessis-orphans/); [CBC 1999](https://www.cbc.ca/news/canada/quebec-ombudsman-says-duplessis-orphans-right-1.173120))","Contrary evidence / limits":"Motive was fiscal, not silencing; but false psychiatric labels discredited survivors' later testimony for decades (the Archbishop demanded case-by-case proof)","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":258},"source_urls":["https://thecanadianencyclopedia.ca/en/article/duplessis-orphans","https://historyofrights.ca/encyclopaedia/main-events/duplessis-orphans/","https://www.cbc.ca/news/canada/quebec-ombudsman-says-duplessis-orphans-right-1.173120"]}],"source_ids":["SRC-9ee26fc4103afcc4","SRC-d3a0b1664937b2b2","SRC-a6627457b6daee7d"]},{"id":"1903-BR-BARBACENA","revisions":[{"id":"1903-BR-BARBACENA","fields":{"Key":"1903-BR-BARBACENA","Country / period":"Brazil (Minas Gerais), 1903–1980s; closed 25 May 2026","Mechanism":"Hospital Colônia de Barbacena: admissions \"sem critério\" — political militants, \"desafetos\" (personal enemies), unmarried mothers, homosexuals, the poor; \\~70% without a psychiatric diagnosis; \\~60,000 deaths; 1,853 bodies sold to medical schools 1969–80; some admissions signed by police delegates","What is documented":"Investigative record: Arbex, *Holocausto Brasileiro* (2013) and Tribuna de Minas series (2011); Ratton's 1979 film ([Tribuna de Minas, Portuguese](https://tribunademinas.com.br/?p=66135); [Conselho Federal de Psicologia](https://site.cfp.org.br/?p=27644); [closure, May 2026](https://www.portaltela.com/noticias/geral/2026/05/25/hospital-psiquiatrico-que-inspirou-holocausto-brasileiro-e-desativado/))","Finding or status":"Journalistic, not judicial; no prosecutions located (\"50 anos sem punição\"); political admissions are asserted, not quantified","Contrary evidence / limits":"VERIFIED (secondary, local-language)","Label":""},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":259},"source_urls":["https://tribunademinas.com.br/?p=66135","https://site.cfp.org.br/?p=27644","https://www.portaltela.com/noticias/geral/2026/05/25/hospital-psiquiatrico-que-inspirou-holocausto-brasileiro-e-desativado/"]}],"source_ids":["SRC-2497c48588b09384","SRC-e794cd8358184fe7","SRC-f2632eadf591e1e4"]},{"id":"1991-CU-BROWN-LAGO","revisions":[{"id":"1991-CU-BROWN-LAGO","fields":{"Key":"1991-CU-BROWN-LAGO","Country / period":"Cuba, 1960s–1980s","Mechanism":"Psychiatric confinement of dissidents (Mazorra)","What is documented":"Brown & Lago, *The Politics of Psychiatry in Revolutionary Cuba* (1991)","Finding or status":"Book-length documentation; AAAS involvement","Contrary evidence / limits":"Single-source dominance","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":260},"source_urls":[]}],"source_ids":[]},{"id":"2016-KR-CONSTITUTIONAL","revisions":[{"id":"2016-KR-CONSTITUTIONAL","fields":{"Key":"2016-KR-CONSTITUTIONAL","Country / period":"South Korea, 2016","Mechanism":"Guardian-initiated involuntary admission (Mental Health Act art. 24)","What is documented":"Constitutional Court found the provision unconstitutional; 2017 law revision","Finding or status":"Judicial finding","Contrary evidence / limits":"Verify date and holding","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":266},"source_urls":[]},{"id":"2016-KR-CONSTITUTIONAL","fields":{"Key":"2016-KR-CONSTITUTIONAL","Country / period":"South Korea, 29 Sep 2016 (2014헌가9)","Mechanism":"Guardian-initiated commitment (구 정신보건법 §24: two guardians' consent plus one psychiatrist's diagnosis)","What is documented":"Applicant committed Nov 2013 on her two children's consent; the Court noted guardians could collude with a psychiatrist, that this \"often occurred and became a social problem,\" and that private \"emergency transport\" firms kidnapped and assaulted people","Finding or status":"JUDICIAL FINDING: unanimous nonconformity ruling; 2016–17 law revision adds dual diagnosis, two-week diagnostic admission and admission-suitability review within one month ([Medigate News, 29 Sep 2016, Korean](https://medigatenews.com/news/2286485391); [PSPD commentary, Korean](https://peoplepower21.org/judiciary/1452956); [Ministry statement 2016, Korean](https://www.incheon.go.kr/welfare/WE010221/1933931))","Limits":"Reform law kept a family-initiated route (§43); 69,220 guardian admissions in 2016 per one study","Label":"VERIFIED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":292},"source_urls":["https://medigatenews.com/news/2286485391","https://peoplepower21.org/judiciary/1452956","https://www.incheon.go.kr/welfare/WE010221/1933931"]}],"source_ids":["SRC-5f8eac9703f5f694","SRC-c46f4e7e4e4b4b2c","SRC-94791b7a282298c7"]},{"id":"1984-JP-UTSUNOMIYA","revisions":[{"id":"1984-JP-UTSUNOMIYA","fields":{"Key":"1984-JP-UTSUNOMIYA","Country / period":"Japan, 1984–1987","Mechanism":"Private hospital deaths; long-stay \"social hospitalization\"; pre-1950 home confinement","What is documented":"Utsunomiya scandal prompted 1987 Mental Health Act","Finding or status":"Official/legislative","Contrary evidence / limits":"—","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":267},"source_urls":[]},{"id":"1984-JP-UTSUNOMIYA","fields":{"Key":"1984-JP-UTSUNOMIYA","Country / period":"Japan (Tochigi), 1984–1987","Mechanism":"Private hospital abuse","What is documented":"Patients beaten to death by staff; UN Sub-Commission and ICJ missions; 1987 Mental Health Act creates designated physicians, voluntary admission, Psychiatric Review Boards","Finding or status":"Official legislative chronology ([MHLW 2009, Japanese](https://www.mhlw.go.jp/shingi/2009/07/dl/s0730-11b_0001.pdf); [Cabinet Office paper, Japanese](https://www8.cao.go.jp/shougai/suishin/kaikaku/s_kaigi/k_16/pdf/s2.pdf))","Limits":"Reform did not end abuse: MHLW's first survey found 72 suspected abuse cases 2015–19; Takiyama Hospital (Hachioji) 2023 assaults and falsified death certificates ([ben54.jp, Japanese](https://www.ben54.jp/news/2100))","Label":"VERIFIED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":294},"source_urls":["https://www.mhlw.go.jp/shingi/2009/07/dl/s0730-11b_0001.pdf","https://www8.cao.go.jp/shougai/suishin/kaikaku/s_kaigi/k_16/pdf/s2.pdf","https://www.ben54.jp/news/2100"]}],"source_ids":["SRC-5fa183968f25032c","SRC-1357d7f19bb8ea96","SRC-11a06891e29921d5"]},{"id":"1977-ZA-APARTHEID","revisions":[{"id":"1977-ZA-APARTHEID","fields":{"Key":"1977-ZA-APARTHEID","Country / period":"South Africa, 1970s","Mechanism":"Private Smith Mitchell institutions holding mostly Black patients","What is documented":"WHO 1977 report *Apartheid and Mental Health Care*; APA 1979 visit","Finding or status":"Official international reports","Contrary evidence / limits":"Conditions and segregation, not silencing of speakers","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":268},"source_urls":[]}],"source_ids":[]},{"id":"2019-NG-SHACKLING","revisions":[{"id":"2019-NG-SHACKLING","fields":{"Key":"2019-NG-SHACKLING","Country / period":"Nigeria and others, 2010s","Mechanism":"Chaining in religious and state facilities","What is documented":"HRW 2019 and 2020 global shackling reports","Finding or status":"NGO finding","Contrary evidence / limits":"Welfare abuse, not political","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":2,"provenance":{"document_id":"DOC-815c9747822d7c19","line":269},"source_urls":[]}],"source_ids":[]},{"id":"2016-US-50-STATE-HOLDS","revisions":[{"id":"2016-US-50-STATE-HOLDS","fields":{"Key":"2016-US-50-STATE-HOLDS","Jurisdiction / date":"All 50 states + D.C., laws as of 2014/2016","Mechanism":"Emergency hold statutes","What is documented":"Every state has one; durations run from 23 hours to 10 days, 72 hours in 22 states; five states do not guarantee assessment by a qualified mental health professional; neither presentation to a judge nor prompt judicial review is uniformly required; 1.27–1.44 million emergency detentions a year nationally, 2013–2015","Finding or status":"Peer-reviewed data set ([Hedman et al., Psychiatric Services 2016](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.201500205); [\"Reasonable or Random\", 2021](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.202000284)); open data at LawAtlas","Limits":"Describes the instrument, not its misuse; no state records referral context","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":277},"source_urls":["https://ps.psychiatryonline.org/doi/10.1176/appi.ps.201500205","https://ps.psychiatryonline.org/doi/10.1176/appi.ps.202000284"]}],"source_ids":["SRC-26468d869b5cc213","SRC-605198dc0d1793fa"]},{"id":"2007-US-MI-DENHOF","revisions":[{"id":"2007-US-MI-DENHOF","fields":{"Key":"2007-US-MI-DENHOF","Jurisdiction / date":"Michigan (Grand Rapids), 2001–2007","Mechanism":"Police FITNESS-FOR-DUTY exam","What is documented":"Officer Patricia Denhof, a plaintiff in a sex-discrimination suit, was ordered to an exam after her court testimony; the department psychologist had told the chief that about 75% of officers examined are found unfit; badge and gun confiscated","Finding or status":"JUDICIAL FINDING: jury found retaliation; Sixth Circuit affirmed ([Denhof v. City of Grand Rapids, 494 F.3d 534](https://caselaw.findlaw.com/court/us-6th-circuit/1379192.html))","Limits":"Civil-rights retaliation, not commitment","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":278},"source_urls":["https://caselaw.findlaw.com/court/us-6th-circuit/1379192.html"]}],"source_ids":["SRC-46f163af56d58fcd"]},{"id":"2011-US-MD-BLAKE","revisions":[{"id":"2011-US-MD-BLAKE","fields":{"Key":"2011-US-MD-BLAKE","Jurisdiction / date":"Maryland (Baltimore County), 2006–2011","Mechanism":"Police fitness exam and medical-records demand","What is documented":"Officer William Blake ordered to a fitness exam the day after testifying; county dropped the demand only after suit; DOJ investigating the county's practices","Finding or status":"JUDICIAL FINDING: $225,000 jury verdict for retaliation, affirmed 4th Cir. ([Daily Record, 2011](https://origintdrdev.wpengine.com/2011/07/17/4th-circuit-affirms-225000-jury-verdict-awarded-to-police-officer))","Limits":"—","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":279},"source_urls":["https://origintdrdev.wpengine.com/2011/07/17/4th-circuit-affirms-225000-jury-verdict-awarded-to-police-officer"]}],"source_ids":["SRC-bfa40f85a7c5e652"]},{"id":"2003-US-IL-MAYORAL-EXAM","revisions":[{"id":"2003-US-IL-MAYORAL-EXAM","fields":{"Key":"2003-US-IL-MAYORAL-EXAM","Jurisdiction / date":"Illinois (village, 7th Cir.), c. 2003–2004","Mechanism":"Police fitness exam","What is documented":"Officer ordered to an intrusive exam after narrowly losing an election to the incumbent mayor; psychologist advised that refusal should be deemed unfitness for \"undermining the quasi-military hierarchical structure\"","Finding or status":"Seventh Circuit reversed dismissal; jury selected on remand ([AELE digest](https://aele.org/psych2004.php))","Limits":"Case name and outcome to confirm","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":280},"source_urls":["https://aele.org/psych2004.php"]}],"source_ids":["SRC-ffb18737ce328f00"]},{"id":"2003-US-FED-JURY-325K","revisions":[{"id":"2003-US-FED-JURY-325K","fields":{"Key":"2003-US-FED-JURY-325K","Jurisdiction / date":"US federal district (county employee), 2003","Mechanism":"FITNESS-FOR-DUTY","What is documented":"Jury found the county unlawfully ordered a psychiatric exam and retaliated for a harassment complaint","Finding or status":"JUDICIAL FINDING: $325,000 ([AELE digest](https://aele.org/psych2004.php))","Limits":"Jurisdiction to confirm","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":281},"source_urls":["https://aele.org/psych2004.php"]}],"source_ids":["SRC-ffb18737ce328f00"]},{"id":"2019-US-OR-SPRINGFIELD","revisions":[{"id":"2019-US-OR-SPRINGFIELD","fields":{"Key":"2019-US-OR-SPRINGFIELD","Jurisdiction / date":"Oregon (Springfield), 2019–2020","Mechanism":"Police fitness exam","What is documented":"Officer Stone ordered to a psychological exam within a month of a finding against him after he challenged colleagues' misconduct","Finding or status":"SETTLEMENT $250,000 ([Insurance Journal, 2021](https://amp.insurancejournal.com/news/west/2021/03/02/603368.htm))","Limits":"No liability established","Label":"SETTLEMENT"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":282},"source_urls":["https://amp.insurancejournal.com/news/west/2021/03/02/603368.htm"]}],"source_ids":["SRC-d42c7cc803f86d64"]},{"id":"2023-US-MO-ASHLAND","revisions":[{"id":"2023-US-MO-ASHLAND","fields":{"Key":"2023-US-MO-ASHLAND","Jurisdiction / date":"Missouri (Ashland), 2023–2025","Mechanism":"Ordered fitness exam never scheduled; dismissal","What is documented":"Officer Whitener reported the chief breaking the law; told to undergo a psychological exam, then fired without statutory process","Finding or status":"SETTLEMENT $1,000,000 ([ABC 17, 2025](https://abc17news.com/?p=1621197))","Limits":"Settlement; claim was procedural","Label":"SETTLEMENT"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":283},"source_urls":["https://abc17news.com/?p=1621197"]}],"source_ids":["SRC-d4f7c32e3f9eadff"]},{"id":"2026-US-MN-DULUTH","revisions":[{"id":"2026-US-MN-DULUTH","fields":{"Key":"2026-US-MN-DULUTH","Jurisdiction / date":"Minnesota (Duluth), filed 1 Mar 2026","Mechanism":"Fitness exam after confidential reports","What is documented":"Lt. Drozdowski, head of the behavioral health unit, reassigned, placed on leave and ordered to an exam after reporting officer misconduct; cleared by internal investigation yet still ordered","Finding or status":"ALLEGATION (pending) ([Hoodline, 2026](https://hoodline.com/2026/03/duluth-cop-says-city-put-him-on-ice-for-blowing-the-whistle/))","Limits":"Filed, untested","Label":"ALLEGATION"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":284},"source_urls":["https://hoodline.com/2026/03/duluth-cop-says-city-put-him-on-ice-for-blowing-the-whistle/"]}],"source_ids":["SRC-d96059d435d4bb34"]},{"id":"1883-JP-SOMA-INCIDENT","revisions":[{"id":"1883-JP-SOMA-INCIDENT","fields":{"Key":"1883-JP-SOMA-INCIDENT","Country / period":"Japan, 1883–1895","Mechanism":"Family confinement of a feudal lord","What is documented":"Retainer Nishikori Gōsei alleged Lord Sōma Tomotane was wrongfully confined by relatives in an inheritance dispute; the scandal produced the 1900 Mental Patients' Custody Act, which legalized home confinement (私宅監置) for 50 years","Finding or status":"Legislative history ([Taiwanese legal abstract](https://lawdata.com.tw/tw/detail.aspx?no=275999); [Utsunomiya, JSSW 2009, Japanese](https://www.jssw.jp/archives/event/conference/2009/57/abstract_57/independent-research/H2_3_1.pdf))","Limits":"The founding Japanese case is a family-inheritance dispute — direct parallel to Packard","Label":"SUPPORTED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":293},"source_urls":["https://lawdata.com.tw/tw/detail.aspx?no=275999","https://www.jssw.jp/archives/event/conference/2009/57/abstract_57/independent-research/H2_3_1.pdf"]}],"source_ids":["SRC-5ae22f943de20a7b","SRC-75286b4ea4b659d2"]},{"id":"2017-FIDH-POST-SOVIET","revisions":[{"id":"2017-FIDH-POST-SOVIET","fields":{"Key":"2017-FIDH-POST-SOVIET","Country / period":"Russia, Crimea, Kazakhstan, Uzbekistan, Jun 2012–Apr 2017","Mechanism":"Forensic evaluation and compulsory treatment","What is documented":"Named cases: Ilmi Umerov (Crimea); Natalia Ulasik, Zinaida Mukhortova, Alexander Bondarenko, Lyudmila Khromina (Kazakhstan); Mikhail Kosenko, Maxim Panfilov, Stanislav Klykh and nine others (Russia); Jamshid Karimov, Elena Urlaeva (Uzbekistan)","Finding or status":"NGO report ([FIDH / Civic Solidarity Platform, April 2017](https://civicsolidarity.org/wp-content/uploads/2017/05/pol-abuse-eng-april-2017-full.pdf))","Limits":"Case-by-case; the report itself calls them \"alleged\"","Label":"VERIFIED (NGO)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":307},"source_urls":["https://civicsolidarity.org/wp-content/uploads/2017/05/pol-abuse-eng-april-2017-full.pdf"]}],"source_ids":["SRC-c66f0b0e06154619"]},{"id":"2022-IR-WLF-PSYCHIATRIC","revisions":[{"id":"2022-IR-WLF-PSYCHIATRIC","fields":{"Key":"2022-IR-WLF-PSYCHIATRIC","Country / period":"Iran, 2016–2024","Mechanism":"Transfer of prisoners and protesters to psychiatric hospitals (Aminabad, Razi); judicial \"diagnosis\" as sentence","What is documented":"Kianoush Sanjari chained to a bed two weeks at Aminabad; Hengameh Shahidi sent to Aminabad instead of a medical hospital; a student transferred 16 Nov 2022 without notice to family or lawyer; Saman Yasin hospitalized 23 Jul 2023, two days after his prison audio message about torture; three actresses judicially \"diagnosed\" with mental illness in Jul 2023 for appearing unveiled; Roya Zakeri sent to Razi in Oct 2023 after filmed slogans; student Ahoo Daryaei transferred after a Nov 2024 undress protest","Finding or status":"NGO documentation ([CHRI, 4 Nov 2024](https://iranhumanrights.org/2024/11/student-who-undressed-to-protest-irans-repressive-dress-code-joins-other-dissidents-forced-into-psychiatric-centers/); [Iran International](https://old.iranintl.com/en/iran/more-political-prisoners-being-moved-psychiatric-hospitals)); Amnesty reports electric shocks and beatings in such transfers","Limits":"No independent access to records; state media's \"mentally ill\" labeling is itself part of the mechanism","Label":"VERIFIED (NGO)"},"section":"Worldwide register by region (Batch 2)","batch":3,"provenance":{"document_id":"DOC-815c9747822d7c19","line":308},"source_urls":["https://iranhumanrights.org/2024/11/student-who-undressed-to-protest-irans-repressive-dress-code-joins-other-dissidents-forced-into-psychiatric-centers/","https://old.iranintl.com/en/iran/more-political-prisoners-being-moved-psychiatric-hospitals"]}],"source_ids":["SRC-313eabf0d6ae5fd8","SRC-881476e9083b8bf9"]},{"id":"1968-RO-PARASCHIV","revisions":[{"id":"1968-RO-PARASCHIV","fields":{"Key":"1968-RO-PARASCHIV","Country / period":"Romania, 1968–1989","Mechanism":"Securitate-directed psychiatric confinement; Decree 313 of 14 Oct 1980 on \"dangerous psychiatric patients\"","What is documented":"Worker Vasile Paraschiv quit the Party publicly in 1968, wrote to the Central Committee in 1971 and tried to found a free trade union; confined to psychiatric hospitals (1978 onward) and forcibly injected with neuroleptics without psychiatric symptoms; psychiatrist Ion Vianu, after emigrating in 1977, joined the Geneva Initiative and described the \"Ceaușescu doctrine\" that only a madman could imagine socialism perishing, with healthy people confined for months or years, not only around state visits; Poiana Mare hospital notorious for dissident detention","Finding or status":"Securitate files at CNSAS; Presidential Commission (Tismăneanu) report 2006 names Paraschiv's 1978 case as the first proven in the West; US State Department cables (Reagan Library) record dissidents confined for political and religious beliefs; Amnesty reports (UK National Archives file) ([Radio Romania International](https://rri.ro/en/features-and-reports/the-history-show/political-psychiatry-in-communist-romania-id128387.html); [Hotnews, Andrei Ursu on Vianu (Romanian)](https://hotnews.ro/opinie-de-andrei-ursu-o-misiune-de-constiinta-lasata-de-ion-vianu-1527783); [Evenimentul Zilei (Romanian)](https://evz.ro/securitatea-lui-ceausescu-il-obliga-pe-vasile-paraschiv-sa-ia-un-tratament-care-sa-l-transforme-in-nebun-adevarat.html); [Reagan Library cables](https://www.reaganlibrary.gov/sites/default/files/2025-02/40-145-39146857-R05-021-2024_1.pdf))","Contrary evidence / limits":"Prosecutors declined to charge Paraschiv's torturers (IICCR complaint 2010); no criminal finding","Label":"VERIFIED (secondary, local-language)"},"section":"Worldwide register by region (Batch 2)","batch":4,"provenance":{"document_id":"DOC-815c9747822d7c19","line":314},"source_urls":["https://rri.ro/en/features-and-reports/the-history-show/political-psychiatry-in-communist-romania-id128387.html","https://hotnews.ro/opinie-de-andrei-ursu-o-misiune-de-constiinta-lasata-de-ion-vianu-1527783","https://evz.ro/securitatea-lui-ceausescu-il-obliga-pe-vasile-paraschiv-sa-ia-un-tratament-care-sa-l-transforme-in-nebun-adevarat.html","https://www.reaganlibrary.gov/sites/default/files/2025-02/40-145-39146857-R05-021-2024_1.pdf"]}],"source_ids":["SRC-1c03c989f5c365f8","SRC-1f79a8bb0d5a4d31","SRC-cedc9ce493415c88","SRC-0fd019838896c53e"]},{"id":"1963-CU-MAZORRA","revisions":[{"id":"1963-CU-MAZORRA","fields":{"Key":"1963-CU-MAZORRA","Country / period":"Cuba, 1963–1980s","Mechanism":"State Security interrogation (Villa Marista) followed by forensic-ward confinement at Havana Psychiatric Hospital (Mazorra) and Gustavo Machín (Santiago); electroshock","What is documented":"Brown & Lago documented 27–31 dissidents (sources differ) diagnosed with conditions such as \"apathy toward socialism\"; nurse Heriberto Mederos named by ten victims","Finding or status":"Book-length investigation (Freedom House, 1991); JUDICIAL FINDING: a US federal jury convicted Mederos \\[corrected, Batch 18/D03: the offence was unlawful procurement of naturalization through false statements about persecution and Party membership; he died before sentencing; the verdict's necessary findings on electroshock are a LEAD — original wording follows\\] in 2002 of lying to immigration officials by denying he administered electroshock to political prisoners ([Cubanet](https://www.cubanet.org/htdocs/CNews/y02/ago02/09e6.htm); [Seattle Times, 1992](https://archive.seattletimes.com/archive/19920506/1490272/electroshock-torture-in-cuba-alleged----ex-political-prisoners-say-they-were-subjected-to-it); [JAAPL review](https://jaapl.org/content/20/2/237))","Contrary evidence / limits":"Amnesty's researcher in 1992: no \"generalized practice\" found, though pressure on certain prisoners \"could have been used\"; Cuban authorities refused APA access to Mazorra","Label":"VERIFIED with DISPUTED scale"},"section":"Worldwide register by region (Batch 2)","batch":4,"provenance":{"document_id":"DOC-815c9747822d7c19","line":315},"source_urls":["https://www.cubanet.org/htdocs/CNews/y02/ago02/09e6.htm","https://archive.seattletimes.com/archive/19920506/1490272/electroshock-torture-in-cuba-alleged----ex-political-prisoners-say-they-were-subjected-to-it","https://jaapl.org/content/20/2/237"]}],"source_ids":["SRC-47ffa2536a29243e","SRC-8e8435864da4c7ed","SRC-97f7c09a9a054ab0"]},{"id":"1977-ZA-APARTHEID-PSYCHIATRY","revisions":[{"id":"1977-ZA-APARTHEID-PSYCHIATRY","fields":{"Key":"1977-ZA-APARTHEID-PSYCHIATRY","Country / period":"South Africa, 1970s–1980s","Mechanism":"Racially segregated institutional confinement; private contractor (Smith, Mitchell & Co.) holding mostly Black long-stay patients; statutory restriction on publishing about institutions","What is documented":"WHO report *Apartheid and Mental Health Care* (MNH/77.5, 1977); APA Special Committee visit report (Am J Psychiatry 136:1498, Nov 1979) confirming \"grossly inferior\" care and \"needless deaths\" among Black patients; RCPsych special committee 1983; Anti-Apartheid Movement campaign for WPA expulsion; 1976 Mental Health Amendment Act criticized as restricting publication about institutions","Finding or status":"International official reports ([AAM archive, \"Which way WPA?\"](https://aamarchives.org/archive/history/1980s/pro04-which-way-wpa/download.html); [Rhodes University thesis, 1989](https://researchrepository.ru.ac.za/items/df46dab0-b3e9-46b8-81b4-8717e8c67967/full); [BJPsych International review](https://www.cambridge.org/core/journals/bjpsych-international/article/reconciliation-and-psychiatry-in-south-africa/D61ADB45B24D13A383EB2C63F9C79914))","Contrary evidence / limits":"Documented as structural neglect and segregation, not confinement of named dissidents; the publication-restriction claim is a LEAD to verify against the 1976 Act's text","Label":"VERIFIED (reports); LEAD (statute)"},"section":"Worldwide register by region (Batch 2)","batch":4,"provenance":{"document_id":"DOC-815c9747822d7c19","line":317},"source_urls":["https://aamarchives.org/archive/history/1980s/pro04-which-way-wpa/download.html","https://researchrepository.ru.ac.za/items/df46dab0-b3e9-46b8-81b4-8717e8c67967/full","https://www.cambridge.org/core/journals/bjpsych-international/article/reconciliation-and-psychiatry-in-south-africa/D61ADB45B24D13A383EB2C63F9C79914"]}],"source_ids":["SRC-1b0544f25d24fe92","SRC-6b98cac490daea17","SRC-93985fe0c382e85d"]},{"id":"1976-AR-PRISON-PSYCHIATRY","revisions":[{"id":"1976-AR-PRISON-PSYCHIATRY","fields":{"Key":"1976-AR-PRISON-PSYCHIATRY","Country / period":"Argentina, 1976–1983","Mechanism":"Psychiatric labeling of legalized political prisoners inside penitentiaries; dismantling of the Federación Argentina de Psiquiatras; disappearance of mental-health professionals","What is documented":"Rafael and Melo's *Locura y suicidio en las cárceles de la dictadura* describes prison psychiatry recast as a control instrument: prisoners classified as \"inestables\", \"peligrosos\", \"paranoicos\" or \"desequilibrados\", which opened the door to isolation and medication, alongside induced despair the authors read as engineered suicide; the junta suppressed community psychiatry it considered leftist while adapting its techniques to promote \"Western and Christian\" values","Finding or status":"Scholarly review ([UNPAZ, *Debates sobre Derechos Humanos*, Spanish](https://publicaciones.unpaz.edu.ar/OJS/index.php/debatesddhh/article/download/2208/2067)); [La Marea on Ramos's research (Spanish)](https://lamarea.com/2013/08/11/la-dictadura-argentina-utilizo-la-psiquiatria-para-esparcir-su-doctrina)","Contrary evidence / limits":"CONADEP (1984) documents disappearances, not psychiatric commitment; psychiatric labeling was ancillary to imprisonment","Label":"SUPPORTED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":5,"provenance":{"document_id":"DOC-815c9747822d7c19","line":323},"source_urls":["https://publicaciones.unpaz.edu.ar/OJS/index.php/debatesddhh/article/download/2208/2067","https://lamarea.com/2013/08/11/la-dictadura-argentina-utilizo-la-psiquiatria-para-esparcir-su-doctrina"]}],"source_ids":["SRC-5f9faa24b991ed73","SRC-1c43734d7b33e4f1"]},{"id":"1973-CL-PSYCHOLOGY-TORTURE","revisions":[{"id":"1973-CL-PSYCHOLOGY-TORTURE","fields":{"Key":"1973-CL-PSYCHOLOGY-TORTURE","Country / period":"Chile, 1973–1990","Mechanism":"Psychologists and physicians advising interrogation and \"national social control\" policy; medical supervision of torture","What is documented":"Twelve interviews with psychologists trained 1973–1990, a Colegio de Psicólogos ethics file, and a dictatorship-era interview show direct and indirect contributions to interrogations; the Colegio Médico's ethics department (Díaz Paci) characterized medical supervision of torture as periodic assessment of the victim's capacity to endure it","Finding or status":"Peer-reviewed ([Revista de Psicología, Universidad de Chile, 2024, Spanish](https://revistaschilenas.uchile.cl/handle/2250/247452?show=full); [Última Década, Spanish](https://ultimadecada.uchile.cl/index.php/RDP/article/download/71967/76848/289826)); Comisión Nacional sobre Prisión Política y Tortura (2004) recorded 38,254 cases of political imprisonment and torture ([Redalyc, Spanish](https://www.redalyc.org/pdf/967/96728593007.pdf))","Contrary evidence / limits":"Chilean psychoanalysis's official histories minimize the period (Asclepio 2014); no documented pattern of confining dissidents in psychiatric hospitals","Label":"SUPPORTED (local-language)"},"section":"Worldwide register by region (Batch 2)","batch":5,"provenance":{"document_id":"DOC-815c9747822d7c19","line":324},"source_urls":["https://revistaschilenas.uchile.cl/handle/2250/247452?show=full","https://ultimadecada.uchile.cl/index.php/RDP/article/download/71967/76848/289826","https://www.redalyc.org/pdf/967/96728593007.pdf"]}],"source_ids":["SRC-ae36831a378fa052","SRC-bfc66fe714a73d18","SRC-3d3bf394200533a2"]},{"id":"1973-UY-BRITOS","revisions":[{"id":"1973-UY-BRITOS","fields":{"Key":"1973-UY-BRITOS","Country / period":"Uruguay, 1973–1985","Mechanism":"Psychiatrist collaboration with military intelligence in prisons","What is documented":"Dolcey Britos, psychiatrist, documented as working with the military regime in the treatment of political prisoners; later subject of professional sanction","Finding or status":"Comparative article ([Polis, Universidad de Los Lagos, Spanish](https://revistas.ulagos.cl/index.php/polis/article/download/751/910/659))","Contrary evidence / limits":"Single secondary source here; SERPAJ *Uruguay Nunca Más* (1989) to open","Label":"LEAD"},"section":"Worldwide register by region (Batch 2)","batch":5,"provenance":{"document_id":"DOC-815c9747822d7c19","line":325},"source_urls":["https://revistas.ulagos.cl/index.php/polis/article/download/751/910/659"]}],"source_ids":["SRC-91d1f81f8de4c18e"]},{"id":"2016-TR-ATK-FORENSIC","revisions":[{"id":"2016-TR-ATK-FORENSIC","fields":{"Key":"2016-TR-ATK-FORENSIC","Country / period":"Turkey, 2016–2025","Mechanism":"Council of Forensic Medicine (ATK) reports declaring sick or psychiatrically ill prisoners \"fit to remain in prison\"; prosecutors overriding release recommendations","What is documented":"Teacher Tuğba Y. reportedly lost her sanity under 24 days of interrogation (Jan 2017), was treated at Bakırköy, then jailed despite medical reports; academic Uysal's psychiatric referral and petitions ignored, ATK report 2024 kept him in prison; İHD counts 1,400+ sick prisoners; Human Rights Foundation of Turkey forensic reports document post-custody psychiatric collapse; Council of Europe torture report blocked from publication for nine years","Finding or status":"NGO and advocacy reporting ([Stockholm Center for Freedom](https://stockholmcf.org/?p=71174); [Turkish Minute, 2017](https://www.turkishminute.com/2017/02/28/teacher-lost-sanity-detention-remains-jail-despite-doctors-reports/); [SCF on TİHV report](https://stockholmcf.org/report-turkish-man-in-police-custody-for-7-days-loses-mental-health/))","Contrary evidence / limits":"The instrument is inverted: forensic authority denies rather than imposes confinement in hospital; sources are exile-advocacy outlets, to be cross-checked against TİHV and İHD originals","Label":"SUPPORTED (advocacy)"},"section":"Worldwide register by region (Batch 2)","batch":6,"provenance":{"document_id":"DOC-815c9747822d7c19","line":333},"source_urls":["https://stockholmcf.org/?p=71174","https://www.turkishminute.com/2017/02/28/teacher-lost-sanity-detention-remains-jail-despite-doctors-reports/","https://stockholmcf.org/report-turkish-man-in-police-custody-for-7-days-loses-mental-health/"]}],"source_ids":["SRC-7732d08547c6f10b","SRC-9c554b772adec9b9","SRC-b59aea670a0887c2"]},{"id":"2001-IN-ERWADI","revisions":[{"id":"2001-IN-ERWADI","fields":{"Key":"2001-IN-ERWADI","Country / period":"India (Tamil Nadu), 6 Aug 2001; Supreme Court 2001–2025","Mechanism":"Custodial neglect in faith-based asylum; chaining; non-implementation of the Mental Health Act 1987","What is documented":"28 chained inmates died in the Erwadi fire after NHRC warnings in May and July 2001; Supreme Court took suo motu cognizance (*In re Death of 25 Chained Inmates*, order 15 Oct 2001), found the 1987 Act \"not at all implemented,\" ordered unchaining and NHRC monitoring; owners sentenced to seven years (2007); Mental Healthcare Act 2017 replaced the 1987 Act; in Oct 2025 the Court again directed NHRC monitoring after chained inmates were found in Budaun; the 1946 Bhore Committee had already called mental hospitals \"mere detention centers\"","Finding or status":"JUDICIAL FINDING and OFFICIAL monitoring ([Supreme Court order text](https://aicb.org.in/images/advocacy/SupremeCourt/In%20Re%20Death%20Of%2025%20Chained%20Inmates%20vs%20Union%20Of%20India%20And%20Ors..PDF); [CLPR case file](https://clpr.org.in/wp-content/uploads/2024/11/67_Asylum_Deaths_v_TN.pdf); [National Herald, 2026](https://www.nationalheraldindia.com/national/the-chains-have-gone-but-the-problem-persists); [IJMR review](https://ijmr.org.in/are-women-with-mental-illness-the-mentally-challenged-adequately-protected-in-india/))","Contrary evidence / limits":"Welfare and custodial failure, not political silencing; included because it shows the complaint-channel failure (NHRC warned, nobody acted) in a non-political setting","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":6,"provenance":{"document_id":"DOC-815c9747822d7c19","line":334},"source_urls":["https://aicb.org.in/images/advocacy/SupremeCourt/In%20Re%20Death%20Of%2025%20Chained%20Inmates%20vs%20Union%20Of%20India%20And%20Ors..PDF","https://clpr.org.in/wp-content/uploads/2024/11/67_Asylum_Deaths_v_TN.pdf","https://www.nationalheraldindia.com/national/the-chains-have-gone-but-the-problem-persists","https://ijmr.org.in/are-women-with-mental-illness-the-mentally-challenged-adequately-protected-in-india/"]}],"source_ids":["SRC-dd2fce715d95de80","SRC-ff417237ca9c24a0","SRC-6d4ed7ec60336830","SRC-671e3fccfeae79a3"]},{"id":"2019-EU-22-COUNTRY","revisions":[{"id":"2019-EU-22-COUNTRY","fields":{"Key":"2019-EU-22-COUNTRY","Country / period":"22 countries (Europe, Australia, New Zealand), 2008–2017","Mechanism":"Comparative involuntary-hospitalisation rates","What is documented":"Median 106.4 per 100,000; Austria highest at 282, Italy lowest at 14.5, Finland 218; England rose from 83.7 (2007–08) to 114.1 (2015–16); **no relationship between rates and any characteristic of the legal framework**, nor with demographic, economic or service indicators","Finding or status":"Peer-reviewed ([Sheridan Rains et al., Lancet Psychiatry 6:403, 2019](https://discovery-pp.ucl.ac.uk/id/eprint/10072450); [open data set](https://data.mendeley.com/datasets/4y9tdf5xxf))","Contrary evidence / limits":"Rates are not misuse; but the finding undercuts the assumption, implicit in every reform in section 6, that procedural safeguards govern how often detention is used","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":6,"provenance":{"document_id":"DOC-815c9747822d7c19","line":335},"source_urls":["https://discovery-pp.ucl.ac.uk/id/eprint/10072450","https://data.mendeley.com/datasets/4y9tdf5xxf"]}],"source_ids":["SRC-e93f55ff0543161a","SRC-4839110a6c7acbde"]},{"id":"2007-NORDIC-HIDDEN-COERCION","revisions":[{"id":"2007-NORDIC-HIDDEN-COERCION","fields":{"Key":"2007-NORDIC-HIDDEN-COERCION","Country / period":"Denmark, Finland, Iceland, Norway, Sweden","Mechanism":"Registration of coercion","What is documented":"Of 6,048 admissions reviewed, 3.3% (Finland) and 11.4% (Norway) of formally *voluntary* admissions were preceded by involuntary referral; published commitment rates therefore underestimate coercion to varying degrees; a 2026 comparative legal analysis finds \"considerable variation\" in Nordic statutes despite shared reputation for rights protection","Finding or status":"Peer-reviewed ([BMC Psychiatry 7(S1):S141, 2007](https://bmcpsychiatry.biomedcentral.com/articles/10.1186/1471-244X-7-S1-S141); [Mijaljica, European Psychiatry 2026](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC13444966/))","Contrary evidence / limits":"Measurement finding; mirrors HL v. UK on \"voluntary\" patients who are not free to leave, and California's voluntary/involuntary boundary","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":6,"provenance":{"document_id":"DOC-815c9747822d7c19","line":336},"source_urls":["https://bmcpsychiatry.biomedcentral.com/articles/10.1186/1471-244X-7-S1-S141","https://www.ncbi.nlm.nih.gov/pmc/articles/PMC13444966/"]}],"source_ids":["SRC-5a23e3a4bd164852","SRC-262e39ca04e20531"]},{"id":"2000-PR-LEY-408","revisions":[{"id":"2000-PR-LEY-408","fields":{"Key":"2000-PR-LEY-408","Jurisdiction / date":"Puerto Rico, Ley 408-2000 (as amended)","Mechanism":"Court-ordered temporary detention and involuntary admission","What is documented":"Any citizen over 18 with \"reasonable basis\" may petition the Court of First Instance (form OAT 1248/1964) for a temporary detention order of up to 24 hours for team evaluation, then court-ordered involuntary admission for up to 15 days, renewable; the petition must disclose the petitioner's economic or litigation interest; specialized mental-health courtrooms and a right to counsel throughout","Finding or status":"Statute and judicial-branch materials ([Ley 408-2000 text](https://docs.pr.gov/files/ASSMCA/Leyes/LEY%20408-2000.pdf); [UPRM summary (Spanish)](https://www.uprm.edu/dcsp/wp-content/uploads/sites/159/2021/05/Ley-408-ley-de-salud-mental.pdf); [Poder Judicial, Salas Especializadas (Spanish)](https://poderjudicial.pr/Documentos/Educo/temas-legales/salud-mental/Servicios-Especializados-atender-asuntos-salud-mental.pdf); [Form OAT 1964, English](https://poderjudicial.pr/Documentos/formularios/OAT-1964-English.pdf))","Limits":"Structural contrast with California: a judge, not an officer or clinician, authorizes even the 24-hour stage; but any private citizen can set the process in motion. No retaliation case law located yet","Label":"VERIFIED (statute)"},"section":"Worldwide register by region (Batch 2)","batch":8,"provenance":{"document_id":"DOC-815c9747822d7c19","line":350},"source_urls":["https://docs.pr.gov/files/ASSMCA/Leyes/LEY%20408-2000.pdf","https://www.uprm.edu/dcsp/wp-content/uploads/sites/159/2021/05/Ley-408-ley-de-salud-mental.pdf","https://poderjudicial.pr/Documentos/Educo/temas-legales/salud-mental/Servicios-Especializados-atender-asuntos-salud-mental.pdf","https://poderjudicial.pr/Documentos/formularios/OAT-1964-English.pdf"]}],"source_ids":["SRC-6ab0cd8aa198c50f","SRC-2cf03c1efeb259d8","SRC-a66821e9944e4873","SRC-50db67fb5875f915"]},{"id":"2020-BY-PUNITIVE-PSYCHIATRY","revisions":[{"id":"2020-BY-PUNITIVE-PSYCHIATRY","fields":{"Key":"2020-BY-PUNITIVE-PSYCHIATRY","Jurisdiction / date":"Belarus, 2020–2025","Mechanism":"Court-ordered compulsory psychiatric treatment in politically motivated criminal cases; secret trials; indefinite confinement; no parole, amnesty or pardon; incommunicado","What is documented":"Viasna counts at least 33 (Apr 2025) and 37 (Nov–Dec 2025) people sentenced to compulsory treatment among 7,840 political sentences; at least 21–25 still confined; one documented case: Matvei Bialyai, who struck the Government House doors with a hammer on 3 Mar 2021, ordered to compulsory treatment three months later and again in 2025","Finding or status":"OFFICIAL FINDING at UN level: Human Rights Council report on Belarus, 22 Apr 2025, para. 37; OHCHR experts' statement 24 Apr 2025 ([EUAA country guidance citing both](https://www.euaa.europa.eu/belarus-political-opposition-and-dissent/331-forced-psychiatric-treatment); [International IDEA tracker](https://www.idea.int/democracytracker/report/belarus/april-2025); [Pozirk/Viasna](https://pozirk.online/en/news/167095); [Nasha Niva on Bialyai](https://nashaniva.com/en/392912); [dissidentby.com case list](https://dissidentby.com/ru/political?page=93))","Limits":"The UN report itself notes secrecy makes it impossible to be certain in each case whether transfer was political or medical","Label":"VERIFIED (UN and NGO)"},"section":"Worldwide register by region (Batch 2)","batch":8,"provenance":{"document_id":"DOC-815c9747822d7c19","line":351},"source_urls":["https://www.euaa.europa.eu/belarus-political-opposition-and-dissent/331-forced-psychiatric-treatment","https://www.idea.int/democracytracker/report/belarus/april-2025","https://pozirk.online/en/news/167095","https://nashaniva.com/en/392912","https://dissidentby.com/ru/political?page=93"]}],"source_ids":["SRC-1f96f08cb71fe797","SRC-3be94e912c7bdfda","SRC-645dcbf3c22edc1d","SRC-4c2c88f7f08d0d57","SRC-47779b6058e6577e"]},{"id":"2009-KZ-MUKHORTOVA","revisions":[{"id":"2009-KZ-MUKHORTOVA","fields":{"Key":"2009-KZ-MUKHORTOVA","Jurisdiction / date":"Kazakhstan (Balkhash), 2009–2013","Mechanism":"Criminal charge for \"deliberately false complaint,\" then court-ordered psychiatric examination, \"delusional disorder\" diagnosis, repeated compulsory hospitalization","What is documented":"Lawyer Zinaida Mukhortova and three colleagues complained to the President in Sept 2009 that MP Nigmatullin had interfered in a civil case; a criminal case followed; a July 2010 forensic exam diagnosed delusional disorder; she was confined over eight months from Jan 2011; after she filed a complaint against the hospital's head doctor (2012), she was taken from her home by four police officers and medical staff on 9 Aug 2013; the Balkhash court's detention order cited her \"possibly querulant\" and \"litigious\" activity; an independent 2012 assessment found her sane; released 1 Nov 2013","Finding or status":"NGO and bar-association findings ([HRW, 15 Aug 2013](https://www.hrw.org/news/2013/08/15/kazakhstan-lawyer-forced-psychiatric-detention); [HRW World Report 2014](https://www.hrw.org/world-report/2014/country-chapters/kazakhstan); [ICJ statement, 3 Sep 2013](https://www.icj.org/wp-content/uploads/2013/09/Statement-Kazakhstan-030913.pdf); [Lawyers for Lawyers](https://www.lawyersforlawyers.org/kazakhstan-forced-psychiatric-confinement-of-zinaida-mukhortova/); [Open Dialogue Foundation](https://en.odfoundation.eu/?p=1245))","Limits":"Kazakh courts upheld the confinement (Karaganda regional court, 27 Sep 2013, in her absence); no domestic finding of retaliation","Label":"VERIFIED (NGO); the closest documented instance anywhere of *complaint → diagnosis → detention → complaint about detention → re-detention*"},"section":"Worldwide register by region (Batch 2)","batch":8,"provenance":{"document_id":"DOC-815c9747822d7c19","line":352},"source_urls":["https://www.hrw.org/news/2013/08/15/kazakhstan-lawyer-forced-psychiatric-detention","https://www.hrw.org/world-report/2014/country-chapters/kazakhstan","https://www.icj.org/wp-content/uploads/2013/09/Statement-Kazakhstan-030913.pdf","https://www.lawyersforlawyers.org/kazakhstan-forced-psychiatric-confinement-of-zinaida-mukhortova/","https://en.odfoundation.eu/?p=1245"]}],"source_ids":["SRC-a1074e0e1396731b","SRC-322be8357c96c989","SRC-6349656281b1213f","SRC-9e3c5515cff0c992","SRC-19b727b5b2cffbef"]},{"id":"1904-ICD-QUERULOUS-PARANOIA","revisions":[{"id":"1904-ICD-QUERULOUS-PARANOIA","fields":{"Key":"1904-ICD-QUERULOUS-PARANOIA","Jurisdiction / date":"Psychiatric nosology, 1879–present","Mechanism":"Diagnostic category: querulous (litigious) paranoia — Krafft-Ebing 1879, Kraepelin 1904; ICD-10 F22.8 *paranoia querulans*","What is documented":"The category fell out of use because, in the words of the standard account, it had been misused to stigmatize people pursuing valid grievances; Lester, Wilson, Griffin and Mullen revived attention in 2004 (\"Unusually persistent complainants,\" BJPsych 184:352) and 2006 (Behavioral Sciences & the Law 24), proposing management by complaints bodies and courts; a published reply, \"In defence of complainants\" (BJPsych 2004), warned that the diagnosis \"runs the risk of misuse by those who wish to use psychiatry as a manner of silencing criticism\" and that complaint merit is judged by each psychiatrist's prejudices","Finding or status":"Peer-reviewed ([Cambridge Core, Lester et al. 2004](https://www.cambridge.org/core/journals/the-british-journal-of-psychiatry/article/unusually-persistent-complainants/83A0E0096877C744C449943DBC3697D5); [reply, \"In defence of complainants\"](https://core-prod.cambridgecore.org/core/product/4176C08F920312798A2B9C02E7A0F17E/core-reader); [Mullen & Lester 2006 abstract](https://zendy.io/title/10.1002/bsl.671); [Monash University Law Review on vexatious-litigant sanctions](https://www.austlii.edu.au/au/journals/MonashULawRw/2008/8.pdf))","Limits":"Lester et al. studied complaints officers' perceptions, not independently verified complaint merit (the reply's central objection); the category is in ICD-10 but not DSM-5","Label":"VERIFIED — the one diagnostic category whose own definition is the act of complaining"},"section":"Worldwide register by region (Batch 2)","batch":8,"provenance":{"document_id":"DOC-815c9747822d7c19","line":353},"source_urls":["https://www.cambridge.org/core/journals/the-british-journal-of-psychiatry/article/unusually-persistent-complainants/83A0E0096877C744C449943DBC3697D5","https://core-prod.cambridgecore.org/core/product/4176C08F920312798A2B9C02E7A0F17E/core-reader","https://zendy.io/title/10.1002/bsl.671","https://www.austlii.edu.au/au/journals/MonashULawRw/2008/8.pdf"]}],"source_ids":["SRC-00460b94d772fbf5","SRC-730287f576729822","SRC-a6a1d81e44cfcf6f","SRC-cf13802d5b12a070"]},{"id":"1962-CA-SF-FRANK","revisions":[{"id":"1962-CA-SF-FRANK","fields":{"Key":"1962-CA-SF-FRANK","Jurisdiction / date":"San Francisco, 1962–63","Channel":"3","Mechanism":"Pre-LPS commitment; insulin coma and ECT","What is documented":"Leonard Roy Frank, 29, committed on a \"paranoid schizophrenia\" diagnosis and given about 50 insulin comas and 35 electroshocks; he later co-founded NAPA (Dec 1973) and edited *The History of Shock Treatment*","Finding or status":"Survivor account and movement biographies ([Wikipedia with Andre and Warren citations](https://en.wikipedia.org/wiki/Leonard_Roy_Frank); [Street Spirit profile](https://freedom-center.willhall.net/pdf/leonardroyfrankstreetspirit.pdf))","Limits":"Family role in the commitment and the facility (Twin Pines, Belmont) to confirm from his own writings","Label":"SUPPORTED; LEAD on initiator"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":369},"source_urls":["https://en.wikipedia.org/wiki/Leonard_Roy_Frank","https://freedom-center.willhall.net/pdf/leonardroyfrankstreetspirit.pdf"]}],"source_ids":["SRC-471f8ad850dfed0d","SRC-a55d6c4918c2d1f8"]},{"id":"1972-CA-MNN-NAPA","revisions":[{"id":"1972-CA-MNN-NAPA","fields":{"Key":"1972-CA-MNN-NAPA","Jurisdiction / date":"San Francisco / Berkeley, 1972–1986","Channel":"3","Mechanism":"Survivor press and organizing","What is documented":"*Madness Network News* founded 1972 by two women inmates of Agnews State Hospital, published to 1986; NAPA (Frank and Wade Hudson) organized protests that for a time stopped ECT in San Francisco; the movement began with the Insane Liberation Front (Portland, 1970)","Finding or status":"Archival ([Mad in America history](https://www.madinamerica.com/2021/01/madness-network-news/); [Oskar Diethelm Library exhibit](https://oskardiethelm.omeka.net/exhibits/show/patient-perspectives-and--anti/-anti-psychiatry--communicatio))","Limits":"MNN's run (1972–86) is the single richest unsearched California case source; Batch 11 should read the issues for named 5150 and conservatorship cases","Label":"VERIFIED (archive located)"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":370},"source_urls":["https://www.madinamerica.com/2021/01/madness-network-news/","https://oskardiethelm.omeka.net/exhibits/show/patient-perspectives-and--anti/-anti-psychiatry--communicatio"]}],"source_ids":["SRC-cb6754cdbd3675e9","SRC-bc144699787315f4"]},{"id":"1982-CA-BERKELEY-MEASURE-T","revisions":[{"id":"1982-CA-BERKELEY-MEASURE-T","fields":{"Key":"1982-CA-BERKELEY-MEASURE-T","Jurisdiction / date":"Berkeley, Nov 1982","Channel":"3","Mechanism":"Municipal ballot ban on ECT","What is documented":"Coalition to Stop Electroshock (Ted Chabasinski, d. 6 Nov 2025) qualified Measure T; passed by a wide margin; the APA spent $15,000 against it; Chabasinski's argument was that California's ECT consent law was so laxly enforced a ban was needed","Finding or status":"Press and biography ([Wikipedia with NYT/Newsweek citations](https://en.wikipedia.org/wiki/Ted_Chabasinski))","Limits":"The ban was later struck down in court (Northern California Psychiatric Society v. City of Berkeley) — opinion to open","Label":"VERIFIED; LEAD on the overturning"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":371},"source_urls":["https://en.wikipedia.org/wiki/Ted_Chabasinski"]}],"source_ids":["SRC-dbcc417dcd89ac85"]},{"id":"2021-CA-ALAMEDA-DOJ","revisions":[{"id":"2021-CA-ALAMEDA-DOJ","fields":{"Key":"2021-CA-ALAMEDA-DOJ","Jurisdiction / date":"Alameda County, report 22 Apr 2021","Channel":"6 and 2","Mechanism":"Federal civil-rights investigation","What is documented":"US DOJ found constitutional and federal-law violations at John George Psychiatric Hospital and Santa Rita Jail, including placement of people with serious mental illness in restrictive housing, non-therapeutic suicide-watch conditions, and failure to provide community-based services","Finding or status":"OFFICIAL FINDING ([county's response in Babu v. Ahern quoting the report](https://rbgg.com/wp-content/uploads/Babu-Joint-Response-to-April-9-2021-Order-re-Santa-Rita-Jail-COVID-19-Response-04-28-2021-1378-1.pdf))","Limits":"Upgrades 2020-CA-ALAMEDA-DRC from ALLEGATION to a parallel OFFICIAL FINDING; the DOJ letter itself to open","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":372},"source_urls":["https://rbgg.com/wp-content/uploads/Babu-Joint-Response-to-April-9-2021-Order-re-Santa-Rita-Jail-COVID-19-Response-04-28-2021-1378-1.pdf"]}],"source_ids":["SRC-87113884d032a965"]},{"id":"2019-CA-KERN-SUICIDE-WATCH","revisions":[{"id":"2019-CA-KERN-SUICIDE-WATCH","fields":{"Key":"2019-CA-KERN-SUICIDE-WATCH","Jurisdiction / date":"Kern County, 2010s","Channel":"6","Mechanism":"Jail \"suicide watch\" isolation","What is documented":"Hundreds placed each year in single cells 24 hours a day with no treatment and a yoga mat; a county official quoted calling it \"punishment and humiliation\"; one hanging inside a watch cell","Finding or status":"Investigative ([ProPublica / Prison Legal News, 2019](https://www.propublica.org/article/a-jail-increased-extreme-isolation-to-stop-suicides-more-people-killed-themselves))","Limits":"Harm, not retaliation; shows the instrument available for misuse","Label":"VERIFIED (reporting)"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":373},"source_urls":["https://www.propublica.org/article/a-jail-increased-extreme-isolation-to-stop-suicides-more-people-killed-themselves"]}],"source_ids":["SRC-7a88d64be25c54b5"]},{"id":"2014-CA-SANTA-BARBARA-SAFETY-CELL","revisions":[{"id":"2014-CA-SANTA-BARBARA-SAFETY-CELL","fields":{"Key":"2014-CA-SANTA-BARBARA-SAFETY-CELL","Jurisdiction / date":"Santa Barbara County","Channel":"6 and 2","Mechanism":"Jail \"safety cells\"","What is documented":"Disability Rights California found inmates with mental illness held in windowless safety cells \"three days at a time on a repeated basis,\" staff confirming placement was \"not temporary\"; the county called an outlier statewide","Finding or status":"OFFICIAL advocacy report ([DRC via Santa Barbara Independent](https://www.disabilityrightsca.org/node/791))","Limits":"—","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":374},"source_urls":["https://www.disabilityrightsca.org/node/791"]}],"source_ids":["SRC-ddab7c0fa838b257"]},{"id":"2021-CA-SLO-DOJ-AGREEMENT","revisions":[{"id":"2021-CA-SLO-DOJ-AGREEMENT","fields":{"Key":"2021-CA-SLO-DOJ-AGREEMENT","Jurisdiction / date":"San Luis Obispo County, 2018–2021","Channel":"6 and 2","Mechanism":"DOJ settlement terms","What is documented":"Before disciplining a person with serious mental illness, staff must determine whether the conduct stemmed from illness; force and restraints \"prohibited as punishment or retaliation\"","Finding or status":"OFFICIAL (DOJ agreement, [Noozhawk](https://www.noozhawk.com/?p=664571))","Limits":"A written safeguard against the exact misuse the record tracks; compliance data to follow","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":375},"source_urls":["https://www.noozhawk.com/?p=664571"]}],"source_ids":["SRC-86ee985ad523f95c"]},{"id":"2025-CA-DOJ-IMMIGRATION","revisions":[{"id":"2025-CA-DOJ-IMMIGRATION","fields":{"Key":"2025-CA-DOJ-IMMIGRATION","Jurisdiction / date":"California immigration detention facilities, 2025","Channel":"6 and 9","Mechanism":"State DOJ facility review","What is documented":"Detainees receiving mental health care disciplined at a higher rate at some facilities; mental-health reviews not conducted before discipline or segregation; a facility failed to report","Finding or status":"OFFICIAL FINDING ([CA DOJ briefing slides](https://oag.ca.gov/system/files/media/care-comm-briefing-slides-052225.pdf))","Limits":"Correlation, not motive","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":376},"source_urls":["https://oag.ca.gov/system/files/media/care-comm-briefing-slides-052225.pdf"]}],"source_ids":["SRC-00131780fd5f1aae"]},{"id":"2015-US-NY-SUFFOLK-WATCH","revisions":[{"id":"2015-US-NY-SUFFOLK-WATCH","fields":{"Key":"2015-US-NY-SUFFOLK-WATCH","Jurisdiction / date":"Suffolk County, New York (E.D.N.Y.)","Channel":"6 and 1","Mechanism":"Jail suicide watch as discipline","What is documented":"Statistical analysis showed people in disciplinary housing were more likely to be placed and kept on suicide watch after clinicians ordered release; the plaintiff remained longer than 96% of comparable inmates","Finding or status":"JUDICIAL FINDING: jury found the jail confined him to suicide watch without justification, as punishment, violating the Fourteenth Amendment ([NERA case summary](https://www.nera.com/experience/2015/pro-bono-statistical-analysis-of-prisoner-treatment-in-a-jury-tria.html))","Limits":"Case name and docket to confirm","Label":"VERIFIED (secondary); the first adjudicated finding in the record that a *psychiatric placement* itself was used as punishment"},"section":"Worldwide register by region (Batch 2)","batch":10,"provenance":{"document_id":"DOC-815c9747822d7c19","line":377},"source_urls":["https://www.nera.com/experience/2015/pro-bono-statistical-analysis-of-prisoner-treatment-in-a-jury-tria.html"]}],"source_ids":["SRC-58887e15761fe691"]},{"id":"2003-CA-SAN-LEANDRO-BIAS","revisions":[{"id":"2003-CA-SAN-LEANDRO-BIAS","fields":{"Key":"2003-CA-SAN-LEANDRO-BIAS","Jurisdiction / date":"San Leandro / Alameda County, 14 and 23 May 2003; 9th Cir. 28 Nov 2007","Mechanism":"5150 ×2; PURPOSE question not reached","What is documented":"A pro se litigant with a pending matter before a judge was placed on two § 5150 holds nine days apart by the same officer; the second application recorded her statement that she would kill herself if the judge ruled against her; she was examined and released the same evening each time, then sued under § 1983 and Civil Code § 51.7","Finding or status":"JUDICIAL FINDING: probable cause existed; claims REJECTED ([*Bias v. Moynihan*, 9th Cir. opinion](https://cdn.ca9.uscourts.gov/datastore/opinions/2007/11/28/0516752.pdf))","Limits":"The litigation context is the trigger for the hold, exactly the complaint-to-hold sequence the record tracks, but the court's analysis stops at the officer's reasonable belief","Label":"VERIFIED (opinion)"},"section":"Worldwide register by region (Batch 2)","batch":11,"provenance":{"document_id":"DOC-815c9747822d7c19","line":385},"source_urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2007/11/28/0516752.pdf"]},{"id":"2003-CA-SAN-LEANDRO-BIAS","fields":{"Key":"2003-CA-SAN-LEANDRO-BIAS","Speech act":"Pending ruling from the judge she was litigating before","Psychiatric act":"Two § 5150 holds","Interval":"Days before/around the ruling; 9 days apart","Who initiated":"Same officer twice","Outcome label":"REJECTED (probable cause)"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":464},"source_urls":[]}],"source_ids":["SRC-e79142ee433d8dec"]},{"id":"2011-CA-SAN-DIEGO-NGUYEN","revisions":[{"id":"2011-CA-SAN-DIEGO-NGUYEN","fields":{"Key":"2011-CA-SAN-DIEGO-NGUYEN","Jurisdiction / date":"San Diego; S.D. Cal. 3:11-cv-02594; 9th Cir. No. 15-56996, 20 Mar 2017","Mechanism":"5150; First Amendment retaliation claim tried","What is documented":"After a bench trial the court found officers had probable cause under § 5150, used reasonable force, and — on the retaliation count — accepted the officers' testimony that the plaintiff's speech was not a factor in the decision to detain","Finding or status":"JUDICIAL FINDING, REJECTED on the merits ([9th Cir. memorandum](https://cdn.ca9.uscourts.gov/datastore/memoranda/2017/03/20/15-56996.pdf))","Limits":"**The only California case found in eleven batches in which retaliatory motive for a § 5150 hold was adjudicated rather than dismissed on immunity or state-action grounds.** The finding rests on officer credibility at trial; the district-court findings of fact are the document to open","Label":"VERIFIED (memorandum)"},"section":"Worldwide register by region (Batch 2)","batch":11,"provenance":{"document_id":"DOC-815c9747822d7c19","line":386},"source_urls":["https://cdn.ca9.uscourts.gov/datastore/memoranda/2017/03/20/15-56996.pdf"]}],"source_ids":["SRC-9b2e4ca03ece9710"]},{"id":"2000s-CA-FRESNO-LEFAY","revisions":[{"id":"2000s-CA-FRESNO-LEFAY","fields":{"Key":"2000s-CA-FRESNO-LEFAY","Jurisdiction / date":"Fresno; 9th Cir.","Mechanism":"5150 after a domestic call","What is documented":"Hold imposed after the husband reported being \"jumped on\"; summary judgment for the officer on probable cause affirmed","Finding or status":"JUDICIAL FINDING, REJECTED ([*LeFay v. Panabaker*](https://caselaw.findlaw.com/court/us-9th-circuit/1762676.html))","Limits":"Illustrates private-party initiation (Mechanism 6) reaching the courts only on the probable-cause question","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":11,"provenance":{"document_id":"DOC-815c9747822d7c19","line":387},"source_urls":["https://caselaw.findlaw.com/court/us-9th-circuit/1762676.html"]}],"source_ids":["SRC-99533c7018b9e48a"]},{"id":"2019-US-SCOTUS-NIEVES","revisions":[{"id":"2019-US-SCOTUS-NIEVES","fields":{"Key":"2019-US-SCOTUS-NIEVES","Jurisdiction / date":"US Supreme Court, *Nieves v. Bartlett*, 587 U.S. \\_\\_\\_ (2019)","Mechanism":"Doctrine","What is documented":"Probable cause generally defeats a First Amendment retaliatory-arrest claim, with a narrow exception where similarly situated people not engaged in the speech are not arrested","Finding or status":"JUDICIAL (doctrine) ([Justia](https://law.justia.com/cases/federal/us/587/17-1174/))","Limits":"Lower courts have applied the arrest framework to § 5150 detentions by analogy; the effect is that a retaliatory hold with probable cause is close to unreviewable in federal court, matching the state-law closure under § 5278","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":11,"provenance":{"document_id":"DOC-815c9747822d7c19","line":388},"source_urls":["https://law.justia.com/cases/federal/us/587/17-1174/"]}],"source_ids":["SRC-2f643ab2ca0ab327"]},{"id":"2007-2013-CA-BURBANK-DAHLIA","revisions":[{"id":"2007-2013-CA-BURBANK-DAHLIA","fields":{"Key":"2007-2013-CA-BURBANK-DAHLIA","Jurisdiction / date":"Burbank; 9th Cir. en banc 2013","Mechanism":"Adjacent: administrative leave after whistleblowing (no hold)","What is documented":"Detective reported colleagues' abuse of suspects, was threatened, then placed on leave; en banc court overruled *Huppert v. City of Pittsburg* and held such disclosures can be citizen speech","Finding or status":"JUDICIAL (doctrine) ([Public Citizen](https://www.citizen.org/news/federal-appeals-court-reinstates-first-amendment-claim-of-whistleblower-police-officer/))","Limits":"No psychiatric instrument; included because it is the California doctrinal frame for officer-whistleblower retaliation that the Schoolcraft (NY) facts would be litigated under here","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":11,"provenance":{"document_id":"DOC-815c9747822d7c19","line":389},"source_urls":["https://www.citizen.org/news/federal-appeals-court-reinstates-first-amendment-claim-of-whistleblower-police-officer/"]}],"source_ids":["SRC-5d201d0d9f45ca86"]},{"id":"CA-COPR-STRUCTURE","revisions":[{"id":"CA-COPR-STRUCTURE","fields":{"Key":"CA-COPR-STRUCTURE","What exists":"Each county has a Patients' Rights Advocate (W&I § 5500 ff.) with \"no direct or indirect clinical\" role, who investigates complaints in LPS facilities and reports Denial of Rights and ECT data upward to the California Office of Patients' Rights (COPR), operated under DHCS contract","What it produces":"A complaint path that exists at every LPS facility and is explained in county brochures ([San Bernardino DBH brochure](https://www.sbcounty.gov/uploads/DBH/2023/10/Patients%27%20Rights%20Brochure.pdf))","Gap for this record":"The advocate's jurisdiction begins inside the facility; the § 5150 application itself — the moment of initiation — is outside it. A person whose grievance is *why they were brought in* has no designated recipient \\[corrected, Batch 18/D04: COPR handles intake, referral and county appeals but cannot change legal status; whether initiation complaints are accepted is untested\\] for that complaint","Label":"VERIFIED (structure)"},"section":"Worldwide register by region (Batch 2)","batch":12,"provenance":{"document_id":"DOC-815c9747822d7c19","line":397},"source_urls":["https://www.sbcounty.gov/uploads/DBH/2023/10/Patients%27%20Rights%20Brochure.pdf"]}],"source_ids":["SRC-2e901568f1cd4716"]},{"id":"CA-IDR-FORMS","revisions":[{"id":"CA-IDR-FORMS","fields":{"Key":"CA-IDR-FORMS","What exists":"DHCS's Involuntary Detentions Data Report series is built from three quarterly county forms: DHCS 1009 (conservatorships established), DHCS 1010 (admissions by § 5150 category, later retitled \"Involuntary Treatment\"), and a third form covering denial-of-rights reports","What it produces":"Annual statewide and county counts and rates per 10,000, FY 2012-13 through FY 2021-22 ([FY14-15](https://www.dhcs.ca.gov/services/MH/Documents/FY14-15_InvoluntaryDetentionReport.pdf); [FY21-22](https://www.dhcs.ca.gov/services/MH/Documents/FY21-22-IDR.pdf))","Gap for this record":"No field for initiator (officer, clinician, family), referral context, repeat holds, race, or complaint outcome; denial-of-rights data are counts by right denied, not narratives; DHCS notes some counties contract reporting to a sheriff's office or private entity that \"does not report data on the services provided\"","Label":"VERIFIED; LEAD on the third form's number and fields"},"section":"Worldwide register by region (Batch 2)","batch":12,"provenance":{"document_id":"DOC-815c9747822d7c19","line":398},"source_urls":["https://www.dhcs.ca.gov/services/MH/Documents/FY14-15_InvoluntaryDetentionReport.pdf","https://www.dhcs.ca.gov/services/MH/Documents/FY21-22-IDR.pdf"]}],"source_ids":["SRC-19fcaa59af7a35b0","SRC-bfd997a59b5d5224"]},{"id":"CA-REPORTING-BOUNDARY","revisions":[{"id":"CA-REPORTING-BOUNDARY","fields":{"Key":"CA-REPORTING-BOUNDARY","What exists":"Facilities report by county of admission, not county of origin; counties with joint agreements (Sutter/Yuba) are merged","What it produces":"Consistent counting of admissions","Gap for this record":"Cross-county holds (a common pattern when a person is taken from one jurisdiction to another facility) cannot be traced; a hold imposed in county A and received in county B appears only in B's total","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":12,"provenance":{"document_id":"DOC-815c9747822d7c19","line":399},"source_urls":[]}],"source_ids":[]},{"id":"AZ-36-520-INITIATION","revisions":[{"id":"AZ-36-520-INITIATION","fields":{"Key":"AZ-36-520-INITIATION","Instrument":"A.R.S. § 36-520(A): \"any responsible individual may apply for a court-ordered evaluation\" of a person alleged to have a mental disorder and to be unwilling to be evaluated voluntarily; a screening agency then decides whether to petition","What is documented":"Statute and Arizona Supreme Court restatement ([*In re MH2023-004502*, 258 Ariz.](https://case-law.vlex.com/vid/re-mh2023-004502-1105632857))","Finding or status":"—","Why it matters here":"Private-party initiation (Mechanism 6) is the statutory default, not an exception; the only filter is the screening agency","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":407},"source_urls":["https://case-law.vlex.com/vid/re-mh2023-004502-1105632857"]}],"source_ids":["SRC-c7d892bcdec92bb9"]},{"id":"AZ-2024-DIRECT-PETITION","revisions":[{"id":"AZ-2024-DIRECT-PETITION","fields":{"Key":"AZ-2024-DIRECT-PETITION","Instrument":"2024 session law (56th Leg., 2nd Reg. Sess., ch. 152, HB 2744) added a \"\\[SUPERSEDED, Batch 18/D02: this describes the introduced bill HB2744P; the enacted chapter keeps § 36-523(C)(2), filing only by the screening agency, and adds § 36-520(J) applicant notice of denial and reasons. Original wording:\\] direct petition for court-ordered evaluation\": if the screening agency declines to file, the applicant may petition the court directly; it also gives guardians and agents notice and standing in treatment proceedings","What is documented":"Session law ([azleg.gov](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf); [bill text](https://www.azleg.gov/legtext/56leg/2R/bills/HB2744P.pdf))","Finding or status":"—","Why it matters here":"Removes the \\[SUPERSEDED, Batch 18/D02 — the enacted law does not remove the gate; ranking withdrawn. Original wording:\\] clinical filter between a private complainant and the court; the first US jurisdiction in the record to *weaken* the professional gate in the 2020s. Arizona now sits beside Korea pre-2016 and the loi de 1838 in initiation design","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":408},"source_urls":["https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf","https://www.azleg.gov/legtext/56leg/2R/bills/HB2744P.pdf"]}],"source_ids":["SRC-c2c6d9d0f2dc125e","SRC-2247f16f0bd1acdc"]},{"id":"AZ-2025-COE-AMENDMENTS","revisions":[{"id":"AZ-2025-COE-AMENDMENTS","fields":{"Key":"AZ-2025-COE-AMENDMENTS","Instrument":"2025 session law (57th Leg., 1st Reg. Sess., ch. 211, HB 2742) amended §§ 36-520, 36-530, 36-531: a screening agency may not refuse to process an application because no other services were tried; adds procedure for voluntary status during evaluation","What is documented":"Session law ([azleg.gov](https://www.azleg.gov/legtext/57leg/1R/laws/0211.pdf))","Finding or status":"—","Why it matters here":"Further lowers the threshold for processing applications","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":409},"source_urls":["https://www.azleg.gov/legtext/57leg/1R/laws/0211.pdf"]}],"source_ids":["SRC-c964b1d454390ed8"]},{"id":"AZ-36-527-24H-NO-REMEDY","revisions":[{"id":"AZ-36-527-24H-NO-REMEDY","fields":{"Key":"AZ-36-527-24H-NO-REMEDY","Instrument":"§ 36-527(A): a person may not be held more than 24 hours in emergency custody unless a petition is filed; the court of appeals held an extra day's detention did not require vacating the later treatment order","What is documented":"JUDICIAL FINDING ([*In re MH 2006-002044*, 170 P.3d 280 (App. 2007)](https://syfert.com/caselaw/case.php?id=6603957))","Finding or status":"—","Why it matters here":"A time limit without a remedy — the Arizona analogue of California's § 5278 closure","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":410},"source_urls":["https://syfert.com/caselaw/case.php?id=6603957"]}],"source_ids":["SRC-157ae2495c050e21"]},{"id":"AZ-36-533-EVAL-WAIVER","revisions":[{"id":"AZ-36-533-EVAL-WAIVER","fields":{"Key":"AZ-36-533-EVAL-WAIVER","Instrument":"Treatment petitions require two physicians' affidavits after examinations; the court of appeals upheld an order where one physician's \"evaluation\" consisted of two failed interviews with an uncooperative patient, holding the objection waived","What is documented":"JUDICIAL FINDING ([*In re MH 2009-002120* (App. 2010)](https://www.omlaw.com/azapp-blog/postings/2010/involuntarily-committed-mental-health-patients-due-process-rights-are-not-violated-when-a-required/))","Finding or status":"—","Why it matters here":"Non-cooperation can satisfy the examination requirement; relevant to Mechanism 8 (refusal to engage read as symptom)","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":411},"source_urls":["https://www.omlaw.com/azapp-blog/postings/2010/involuntarily-committed-mental-health-patients-due-process-rights-are-not-violated-when-a-required/"]}],"source_ids":["SRC-728f8ab8fc6b03fd"]},{"id":"AZ-MOOTNESS","revisions":[{"id":"AZ-MOOTNESS","fields":{"Key":"AZ-MOOTNESS","Instrument":"Orders routinely expire before appellate review; the Supreme Court decided *MH2023-004502* only under a mootness exception","What is documented":"JUDICIAL","Finding or status":"—","Why it matters here":"Appellate oversight of initiation practices is structurally rare","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":13,"provenance":{"document_id":"DOC-815c9747822d7c19","line":412},"source_urls":[]}],"source_ids":[]},{"id":"2020-AZ-ASH-IOC-RETALIATION","revisions":[{"id":"2020-AZ-ASH-IOC-RETALIATION","fields":{"Key":"2020-AZ-ASH-IOC-RETALIATION","Date":"Arizona State Hospital, IOC annual report 2020","Channel":"2","What is documented":"The statutory Independent Oversight Committee (A.R.S.-mandated) names as its \"primary concern\" that patients \"have consistently voiced concerns over retaliation from some staff after filing grievances\"; the IOC requested video of one retaliation incident and noted it has no investigative power of its own","Finding or status":"OFFICIAL (oversight body) ([IOC 2020 report](https://ioc.az.gov/sites/default/files/2024-09/2020%20ASH%20IOC%20Annual%20Report.pdf))","Limits":"Patient-reported pattern, not adjudicated; the IOC's remedy is referral to the hospital's own complaints office","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":420},"source_urls":["https://ioc.az.gov/sites/default/files/2024-09/2020%20ASH%20IOC%20Annual%20Report.pdf"]}],"source_ids":["SRC-f59dd2b29aaf77da"]},{"id":"2023-AZ-ASH-IOC-RETALIATION","revisions":[{"id":"2023-AZ-ASH-IOC-RETALIATION","fields":{"Key":"2023-AZ-ASH-IOC-RETALIATION","Date":"IOC annual report 2022-23 (1 Nov 2023) and public meeting 19 Oct 2023","Channel":"2","What is documented":"\"Many patients believe there is a risk of retaliation if they file\" grievances; an anonymous letter traced to an active employee alleged fear of retaliation; at the October meeting the chair reported the committee reviewed nursing notes for a grievance case \"to see if there was any evidence of retaliation\" and found the grievance substantiated but could not assess post-grievance retaliation from the records available; a member stated that most grievances \"statistically lead to unfavorable outcomes in the form of an unsubstantiated claim, or retaliation\"","Finding or status":"OFFICIAL (oversight body) ([IOC 2022-23 report](https://ioc.az.gov/sites/default/files/2024-10/DHS%20ASH%20IOC%20Annual%20Report%202022-23.pdf); [19 Oct 2023 minutes](https://ioc.az.gov/sites/default/files/2023-10/IOC_%20DHS_ASH%20IOC%20Meeting%20%282023-10-19%2018_03%20GMT-7%29.pdf))","Limits":"The IOC reads records the hospital chooses to supply; its own report says it cannot conduct investigations","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":421},"source_urls":["https://ioc.az.gov/sites/default/files/2024-10/DHS%20ASH%20IOC%20Annual%20Report%202022-23.pdf","https://ioc.az.gov/sites/default/files/2023-10/IOC_%20DHS_ASH%20IOC%20Meeting%20%282023-10-19%2018_03%20GMT-7%29.pdf"]}],"source_ids":["SRC-b7c19b65dfe45d8f","SRC-ea677586311290ce"]},{"id":"2023-AZ-SB1444-ANTI-RETALIATION","revisions":[{"id":"2023-AZ-SB1444-ANTI-RETALIATION","fields":{"Key":"2023-AZ-SB1444-ANTI-RETALIATION","Date":"2023 session, SB 1444 (State Hospital; administration; oversight)","Channel":"1","What is documented":"Legislation addressing ASH administration and oversight; press reports a provision forbidding staff retaliation, which the IOC called \"a step in the right direction\" needing more","Finding or status":"LEGISLATIVE ([Arizona Republic via Yahoo](https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html))","Limits":"Section text and effective date to open on azleg.gov","Label":"SUPPORTED; LEAD"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":422},"source_urls":["https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html"]}],"source_ids":["SRC-7b943f8c18b2fffa"]},{"id":"2023-AZ-DRAZ-ACCESS-SUIT","revisions":[{"id":"2023-AZ-DRAZ-ACCESS-SUIT","fields":{"Key":"2023-AZ-DRAZ-ACCESS-SUIT","Date":"Filed 12 Sep (2023); settled","Channel":"2 and 4","What is documented":"Disability Rights Arizona (formerly Arizona Center for Disability Law), the PAIMI protection-and-advocacy agency, sued ASH and ADHS for choosing which patients it could speak to, listening to conversations, and withholding peer-review records on injuries and deaths; later settled for facility and patient access","Finding or status":"SETTLEMENT ([DRAZ release](https://disabilityrightsaz.org/?p=37); [unsilenced.org index](https://www.unsilenced.org/?p=21972))","Limits":"Settlement terms to open","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":423},"source_urls":["https://disabilityrightsaz.org/?p=37","https://www.unsilenced.org/?p=21972"]}],"source_ids":["SRC-a7e6bd9112ae9f6f","SRC-66c72de3dd5022d9"]},{"id":"2023-AZ-ASH-DEATH-RECORDS","revisions":[{"id":"2023-AZ-ASH-DEATH-RECORDS","fields":{"Key":"2023-AZ-ASH-DEATH-RECORDS","Date":"Feb 2023","Channel":"9","What is documented":"ADHS refused to release incident reports on two patient suicides, citing HIPAA and A.R.S. confidentiality; critics describe the department operating and overseeing the hospital as \"the fox watching the henhouse\"","Finding or status":"Reporting ([Arizona Republic via Yahoo](https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html))","Limits":"A dataset-gap finding: death reports are the field not disclosed","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":424},"source_urls":["https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html"]}],"source_ids":["SRC-7b943f8c18b2fffa"]},{"id":"2021-AZ-AZCIR-INVESTIGATION","revisions":[{"id":"2021-AZ-AZCIR-INVESTIGATION","fields":{"Key":"2021-AZ-AZCIR-INVESTIGATION","Date":"AZCIR / Amy Silverman, 2021","Channel":"3 and 4","What is documented":"Statewide investigation finds the *Arnold v. Sarn* settlement \"removed most accountability and transparency measures\"; crisis teams understaffed; \"street, treat, repeat\" short hospitalizations; \"claims of retaliation and isolation plague the state mental hospital for patients who file grievances\"; unlicensed boarding homes absorbing the overflow","Finding or status":"Investigative ([Fund for Investigative Journalism summary](https://fij.org/?p=13742))","Limits":"Series itself to open","Label":"VERIFIED (secondary)"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":425},"source_urls":["https://fij.org/?p=13742"]}],"source_ids":["SRC-b93cc0e53aa346c8"]},{"id":"1989-AZ-ASH-CRIPA","revisions":[{"id":"1989-AZ-ASH-CRIPA","fields":{"Key":"1989-AZ-ASH-CRIPA","Date":"25 Sep 1989 – 14 Feb 1995","Channel":"6 and 8","What is documented":"DOJ CRIPA investigation of ASH found deficiencies in bodily restraints, medical care and psychiatric treatment (findings letter 14 Dec 1990); partial compliance by 1993; investigation closed 1995","Finding or status":"OFFICIAL FINDING ([Civil Rights Litigation Clearinghouse](https://clearinghouse.net/case/432/))","Limits":"Historical baseline for the same institution","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":14,"provenance":{"document_id":"DOC-815c9747822d7c19","line":426},"source_urls":["https://clearinghouse.net/case/432/"]}],"source_ids":["SRC-ad96247da725266b"]},{"id":"TX-573-PEACE-OFFICER","revisions":[{"id":"TX-573-PEACE-OFFICER","fields":{"Key":"TX-573-PEACE-OFFICER","Instrument":"Health & Safety Code § 573.001–.002: a peace officer may apprehend without warrant on belief of mental illness and substantial risk of serious harm, and must immediately file a \"Notification of Emergency Detention\" on a statutory form stating the specific conduct relied on; 2013 HB 1738 added rights notices and barred facilities from requiring the officer's continued presence","What is documented":"Statute and bill analysis ([HB 1738 analysis, 83R](https://capitol.texas.gov/tlodocs/83R/analysis/pdf/HB01738S.pdf))","Finding or status":"—","Why it matters here":"The notification form is a written record of the initiating facts — a field California's § 5150 application also has, but which neither state aggregates; the Texas form is the channel-9 target document for any archival pass","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":15,"provenance":{"document_id":"DOC-815c9747822d7c19","line":434},"source_urls":["https://capitol.texas.gov/tlodocs/83R/analysis/pdf/HB01738S.pdf"]}],"source_ids":["SRC-cd39f88bdf47f300"]},{"id":"TX-2015-SB359-FACILITY-HOLD","revisions":[{"id":"TX-2015-SB359-FACILITY-HOLD","fields":{"Key":"TX-2015-SB359-FACILITY-HOLD","Instrument":"2015 SB 359 \\[SUPERSEDED, Batch 18/D01: VETOED by Governor Abbott 2 Jun 2015; the text below describes the engrossed bill, never law. Original wording:\\] (84R) added § 573.005: hospitals, emergency departments and freestanding ERs may detain a person up to four hours without an officer or court order when a physician believes there is no time to file; a notice of detention goes in the medical record; subsection (h): such detention \"is not considered involuntary psychiatric hospitalization\" for the handgun-license disqualification in Government Code § 411.172(e)","What is documented":"Session law ([SB 359 engrossed](https://www.legis.state.tx.us/tlodocs/84R/billtext/doc/SB00359S.doc))","Finding or status":"—","Why it matters here":"A legislature designing an emergency hold *so that it leaves no firearm-record trace* — Mechanism 4 addressed by statute, in the opposite direction from California's § 8103","Label":"VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":15,"provenance":{"document_id":"DOC-815c9747822d7c19","line":435},"source_urls":["https://www.legis.state.tx.us/tlodocs/84R/billtext/doc/SB00359S.doc"]}],"source_ids":["SRC-afe861a7bd025620"]},{"id":"TX-2023-2025-EXPANSION-BILLS","revisions":[{"id":"TX-2023-2025-EXPANSION-BILLS","fields":{"Key":"TX-2023-2025-EXPANSION-BILLS","Instrument":"2023 HB 5210 / SB 2287 / HB 3986 (88R) proposed letting non-physician mental health professionals file emergency-detention applications without a peace officer and extending facility temporary detention, with evidence to be presented to a court within four hours; 2025 HB 5463 (89R) revises the notification form","What is documented":"Bill texts ([HB 5210](https://capitol.texas.gov/tlodocs/88R/billtext/html/HB05210I.htm); [SB 2287](https://capitol.texas.gov/tlodocs/88R/billtext/pdf/SB02287S.pdf); [HB 5463](https://capitol.texas.gov/tlodocs/89R/billtext/pdf/HB05463I.pdf))","Finding or status":"—","Why it matters here":"Direction of travel is toward more initiators and longer no-order holds; enactment status of each to confirm","Label":"VERIFIED (texts); LEAD (enactment)"},"section":"Worldwide register by region (Batch 2)","batch":15,"provenance":{"document_id":"DOC-815c9747822d7c19","line":436},"source_urls":["https://capitol.texas.gov/tlodocs/88R/billtext/html/HB05210I.htm","https://capitol.texas.gov/tlodocs/88R/billtext/pdf/SB02287S.pdf","https://capitol.texas.gov/tlodocs/89R/billtext/pdf/HB05463I.pdf"]}],"source_ids":["SRC-8d2c7011195d2e9f","SRC-48016b62c10e86a2","SRC-74407e4581977205"]},{"id":"2020s-TX-AUSTIN-OPO-FALSE-REPORT","revisions":[{"id":"2020s-TX-AUSTIN-OPO-FALSE-REPORT","fields":{"Key":"2020s-TX-AUSTIN-OPO-FALSE-REPORT","Instrument":"Austin Office of Police Oversight, formal complaint","What is documented":"A complainant alleged APD acted on \"a false report that I was suicidal with a gun\"; the mental health response officer was recorded declining to evaluate him (\"everyone's crazy tonight\"); OPO recommended the allegation for formal classification and cited §§ 573.001–.002","Finding or status":"OFFICIAL complaint record ([City of Austin OPO](https://austintexas.gov/node/82794))","Why it matters here":"A documented instance of the third-party-report trigger (Mechanism 6) reaching a civilian oversight body; outcome to open","Label":"VERIFIED (complaint); outcome LEAD"},"section":"Worldwide register by region (Batch 2)","batch":15,"provenance":{"document_id":"DOC-815c9747822d7c19","line":437},"source_urls":["https://austintexas.gov/node/82794"]}],"source_ids":["SRC-b5f17624e7c10832"]},{"id":"2012-RU-BOLOTNAYA-KOSENKO","revisions":[{"id":"2012-RU-BOLOTNAYA-KOSENKO","fields":{"Key":"2012-RU-BOLOTNAYA-KOSENKO","Jurisdiction / date":"Moscow, May 2012 protest; trial 2013","Channel":"6-reverse","Mechanism":"LONG-COMMITMENT (compulsory treatment)","What is documented":"Mikhail Kosenko, a Bolotnaya Square defendant with a 12-year outpatient history, had his case severed from the others because investigators sought compulsory psychiatric treatment; a Soviet-era dissident testified he had not fought police; Memorial's Orlov called it a political trial","Finding or status":"Court-ordered compulsory treatment; condemned by Memorial and Amnesty ([Wikipedia summary with Yaffa and press citations](https://en.wikipedia.org/wiki/Mikhail_Kosenko))","Label":"VERIFIED (secondary); predates the 2016 start of the Russia rows — the register's Russian resurgence should now begin in 2013"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":445},"source_urls":["https://en.wikipedia.org/wiki/Mikhail_Kosenko"]},{"id":"2012-RU-BOLOTNAYA-KOSENKO","fields":{"Key":"2012-RU-BOLOTNAYA-KOSENKO","Speech act":"Protest attendance","Psychiatric act":"Case severed for compulsory treatment","Interval":"Weeks (investigative stage)","Who initiated":"Investigators","Outcome label":"COURT ORDER"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":469},"source_urls":[]}],"source_ids":["SRC-7982358a4632fb17"]},{"id":"2005-US-3D-CIR-RICHARDS","revisions":[{"id":"2005-US-3D-CIR-RICHARDS","fields":{"Key":"2005-US-3D-CIR-RICHARDS \\[re-keyed 2006-US-VI-RICHARDS, Batch 20/A01: opinion filed 23 Jan 2006, appeal from the District Court of the Virgin Islands\\]","Jurisdiction / date":"US, 3d Cir. (non-precedential, 2005)","Channel":"1-reverse","Mechanism":"COMPETENCY-EXAM (civil, Rule 17(c)); adversary-initiated","What is documented":"A pro se attorney-plaintiff; the defendant university \"suggested the District Court consider\" her competency; the magistrate judge ordered a psychiatrist to address it and appointed a guardian, stripping her of control of her own case; the Third Circuit took jurisdiction on the ground that denial of the right to proceed pro se \"injures dignity\"","Finding or status":"JUDICIAL (interlocutory review granted) ([*Richards v. Duke University*, 3d Cir. 05-1170](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf))","Label":"VERIFIED (opinion); **first row in the record where the opposing party in civil litigation initiated the psychiatric inquiry**"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":446},"source_urls":["https://www2.ca3.uscourts.gov/opinarch/051170np.pdf"]}],"source_ids":["SRC-d7b8137f3b7f5b2d"]},{"id":"2011-US-2D-CIR-JAMES","revisions":[{"id":"2011-US-2D-CIR-JAMES","fields":{"Key":"2011-US-2D-CIR-JAMES","Jurisdiction / date":"US, 2d Cir. 2011","Channel":"1-reverse","Mechanism":"Post-detention discounting (Mechanism 8)","What is documented":"District court dismissed a pro se complaint with prejudice solely because the plaintiff had been adjudicated incapacitated in state court in 2003 and her guardians did not respond; her filings alleged a guardian held a financial interest adverse to hers; the Second Circuit vacated","Finding or status":"JUDICIAL FINDING, REVERSED ([*James v. State of New York*](https://hallapproved.com/us/cases/ca2/2011/212975))","Label":"VERIFIED; shows the guardianship record operating as a bar to the courthouse, with the person's own allegation against the guardian unheard"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":447},"source_urls":["https://hallapproved.com/us/cases/ca2/2011/212975"]}],"source_ids":["SRC-ff67d0334cc08914"]},{"id":"2018-US-MD-MONTGOMERY-VEXATIOUS","revisions":[{"id":"2018-US-MD-MONTGOMERY-VEXATIOUS","fields":{"Key":"2018-US-MD-MONTGOMERY-VEXATIOUS","Jurisdiction / date":"Montgomery County, Maryland; Court of Special Appeals unreported 0037s20","Channel":"1-reverse","Mechanism":"Vexatious-litigant order + guardianship + capacity evaluation","What is documented":"In a guardianship case the county health department petitioned for evaluation of the appellant's mental capacity; the court recounted her \"numerous frivolous, stream-of-consciousness pleadings,\" eight pro se motions, declared her a vexatious litigant, enjoined further self-represented filings, and after a competency hearing again found her unable to manage her affairs; fees were paid from her guardianship estate","Finding or status":"JUDICIAL FINDING ([Maryland unreported opinion](https://www.courts.state.md.us/sites/default/files/unreported-opinions/0037s20.pdf))","Label":"VERIFIED (opinion); the closest US analogue to the Mukhortova court's citation of \"litigious activity\" — filing volume recited in the same order that restricts filing and confirms incapacity"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":448},"source_urls":["https://www.courts.state.md.us/sites/default/files/unreported-opinions/0037s20.pdf"]},{"id":"2018-US-MD-MONTGOMERY-VEXATIOUS","fields":{"Key":"2018-US-MD-MONTGOMERY-VEXATIOUS","Speech act":"Eight pro se motions","Psychiatric act":"Capacity evaluation petitioned; vexatious order","Interval":"Same proceeding","Who initiated":"County health department","Outcome label":"JUDICIAL FINDING"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":472},"source_urls":[]}],"source_ids":["SRC-3cc6dceb23e26127"]},{"id":"2012-US-3D-CIR-POWELL","revisions":[{"id":"2012-US-3D-CIR-POWELL","fields":{"Key":"2012-US-3D-CIR-POWELL","Jurisdiction / date":"US, 3d Cir. 2012","Channel":"4","Mechanism":"COMPETENCY (civil) — contrary direction","What is documented":"A prisoner's psychiatric report put the district court on notice of possible incompetence; the court abused its discretion by not inquiring; reversed","Finding or status":"JUDICIAL ([*Powell v. Symons*](https://www.njd.uscourts.gov/sites/njd/files/Powell.pdf))","Label":"VERIFIED; Rule 17(c) running protectively"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":449},"source_urls":["https://www.njd.uscourts.gov/sites/njd/files/Powell.pdf"]}],"source_ids":["SRC-c26d1b284901383a"]},{"id":"2016-US-6TH-CIR-DUBRULE","revisions":[{"id":"2016-US-6TH-CIR-DUBRULE","fields":{"Key":"2016-US-6TH-CIR-DUBRULE","Jurisdiction / date":"US, 6th Cir. 2016","Channel":"4","Mechanism":"COMPETENCY (criminal) — contrary direction","What is documented":"\"The mere fact that a pro se litigant espouses a far-fetched, or even bizarre, legal-defense theory is insufficient to clear the high hurdle for incompetency\"","Finding or status":"JUDICIAL ([JAAPL note on *United States v. Dubrule*](https://jaapl.org/node/8997))","Label":"VERIFIED; the doctrinal counterweight to the Maryland and Richards rows"},"section":"Worldwide register by region (Batch 2)","batch":16,"provenance":{"document_id":"DOC-815c9747822d7c19","line":450},"source_urls":["https://jaapl.org/node/8997"]}],"source_ids":["SRC-97067248d9a9dc31"]},{"id":"2012-VA-RAUB","revisions":[{"id":"2012-VA-RAUB","fields":{"Key":"2012-VA-RAUB","Speech act":"Facebook posts","Psychiatric act":"Detention","Interval":"Same day","Who initiated":"Police / county","Outcome label":"Petition dismissed as empty"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":467},"source_urls":[]}],"source_ids":[]},{"id":"2013-KZ-MUKHORTOVA","revisions":[{"id":"2013-KZ-MUKHORTOVA","fields":{"Key":"2013-KZ-MUKHORTOVA","Speech act":"Complaint about her own detention","Psychiatric act":"Re-confinement; \"litigious activity\" cited","Interval":"Weeks","Who initiated":"Prosecutor / clinic","Outcome label":"NGO-VERIFIED"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":470},"source_urls":[]}],"source_ids":[]},{"id":"2012-US-10TH-CIR-WITNESS","revisions":[{"id":"2012-US-10TH-CIR-WITNESS","fields":{"Key":"2012-US-10TH-CIR-WITNESS","Speech act":"Scheduled testimony as sole prosecution witness","Psychiatric act":"Involuntary commitment","Interval":"6 days before trial","Who initiated":"Unknown (records withheld)","Outcome label":"JUDICIAL (appellate note on withheld impeachment)"},"section":"Worldwide register by region (Batch 2)","batch":17,"provenance":{"document_id":"DOC-815c9747822d7c19","line":471},"source_urls":[]}],"source_ids":[]},{"id":"US-FED-2015-PETITT","revisions":[{"id":"US-FED-2015-PETITT","fields":{"Key":"US-FED-2015-PETITT","Setting":"Airline (Delta), WA/GA","Hazard":"Fatigue, training records, SMS culture","Instrument (category)":"Section 15 psychiatric evaluation (A)","Initiator; knew of report?":"VP Flight Ops Graham, labor counsel Puckett, DHS Faulkner; yes","Independent assessment":"Mayo panel and neutral examiner contradicted company psychiatrist","Finding, stage, remedy":"ARB affirmed violation and back pay; front pay and $500k vacated; remanded; settlement approved by ALJ 21 Oct 2022, terms confidential","Fate of hazard":"Not stated in decisions","Status":"VERIFIED (merits, settlement fact); LEAD (terms, regulator record on commute-time finding)"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":629},"source_urls":[]}],"source_ids":[]},{"id":"US-FL-1991-DIAZ-ROBAINAS","revisions":[{"id":"US-FL-1991-DIAZ-ROBAINAS","fields":{"Key":"US-FL-1991-DIAZ-ROBAINAS","Setting":"Nuclear (Turkey Point)","Hazard":"Technical safety issues","Instrument (category)":"Psychological fitness order; firing for refusal (A)","Initiator; knew of report?":"Director Hosmer; yes","Independent assessment":"None — refused","Finding, stage, remedy":"Secretary of Labor found retaliation (reversing ALJ), non-final; settled on remand; NRC $100,000 penalty paid 3 Dec 1996","Fate of hazard":"Not stated","Status":"VERIFIED (finding, penalty paid, settlement); LEAD (terms, fate of hazard)"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":630},"source_urls":[]},{"id":"US-FL-1991-DIAZ-ROBAINAS","fields":{"Source account":"Primary: Sec'y of Labor, Decision and Remand Order, 19 Jan 1996: https://kkc.com/wp-content/uploads/2023/02/D-Rv.FPL_.pdf (scanned copy; verify pagination against the reporter). NRC EA 96-051: https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/reactors/ea96051\n1. Person/role: Regino R. Diaz-Robainas (NRC and coworkers use \"Richard\"). Engineer at Florida Power 1980–19 Aug 1991; Lead Engineer, Instrument & Control (1985); Senior Engineer when fired. Turkey Point Nuclear Plant. Engineering role VERIFIED from the decision's own findings.\n2. Concern: disputes with supervisor Bob Wade over replacing pressure transmitters that were to sense a loss-of-cooling accident, and over the Westinghouse setpoint study and ERDADS (a post-TMI operator-information system). \n3. Label: none clinical. Instrument = order to a psychological fitness-for-duty evaluation with the employer's consultant Dr. Dennis Johnson (L3). Informal characterisations in the record (L2): Hosmer saw him as \"overwhelmed and stressed out\"; Wade's appraisal called him not \"practical at times\" and unwilling to entertain others' opinions.\n4. Initiator and stated grounds: John Hosmer, Director of Nuclear Engineering. Grounds shifted: stress and declining performance, then fear of \"sabotage\". Early July 1991 the division president asked managers about employees in performance counselling who might attract \"adverse newspaper or NRC reactions\" and suggested considering fitness for duty. Hosmer acted on 26–30 July after Robainas threatened to go to the Miami Herald.\n5. Sequence: Mar 1990 drug-policy objection; Feb 1991 below-average appraisal and 23 Feb letter alleging retaliation; 30 Apr interim review; 2 May internal Speakout complaint; 30 Jul order; 2 Aug no-show, badge pulled; 9 Aug Hosmer learns of NRC contact; 19 Aug refusal and firing; complaint filed 29 Aug 1991.\n6. Independent assessment and contrary evidence: first-line supervisor Pagnozzi saw him daily and never questioned his fitness; coworkers and the ombudsman saw no instability; Dr. Johnson never met him and had only partial documents. Contrary: the Secretary accepted that the Feb and Apr performance ratings had valid reasons and were not shown pretextual, accepted Robainas had said he was under stress, and agreed Hosmer had a duty to ensure fitness. The ALJ had treated the evaluation as non-punitive.\n7. Findings: ALJ R.D.&O. 29 Oct 1993: dismissed. Secretary 19 Jan 1996: reversed on discharge; \"Hosmer's explanation is a pretext\"; order \"based solely on retaliatory animus\" (quoted by NRC from the Decision at 8). Remanded for remedy; not a final remedy decision. NRC: $100,000 civil penalty (paid 3 Dec 1996, per DD-97-20, carried). Settled before ALJ remedy ruling (carried).\n8. Consequences and hazard: fired; reinstatement and back pay ordered; settled. Fate of hazard (UPGRADED from LEAD): the Secretary records that Florida Power \"ultimately agreed\" and replaced the transmitters, and that the plant eventually agreed with him on ERDADS. The record does not show whether he was credited.\n9. Griffin test: first-line observer saw nothing; the referral decision-maker had seen him twice in 1991. Result: referral not supported by observed behaviour (Secretary's finding).\n10. Remaining uncertainty: settlement terms; whether the setpoint study concern was resolved; the ALJ's full reasoning (not read). Next source: ALJ R.D.&O. 29 Oct 1993.\nStatus: VERIFIED."},"section":"3.1 Diaz-Robainas v. Florida Power & Light, 92-ERA-10 — VERIFIED (primary read in full this batch)","batch":21,"provenance":{"document_id":"DOC-15b8efeaf6dfd366","line":24},"source_urls":["https://kkc.com/wp-content/uploads/2023/02/D-Rv.FPL_.pdf","https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/reactors/ea96051"]}],"source_ids":["SRC-c467cf6390a0bd50","SRC-dcfb32d9f577deaf"]},{"id":"US-FED-1991-CADDELL","revisions":[{"id":"US-FED-1991-CADDELL","fields":{"Key":"US-FED-1991-CADDELL","Setting":"DOJ","Hazard":"Disclosure content unread","Instrument (category)":"Psychiatric fitness exam (A)","Initiator; knew of report?":"Agency","Independent assessment":"Unread","Finding, stage, remedy":"No jurisdiction: pre-1994","Fate of hazard":"Unread","Status":"LEAD"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":631},"source_urls":[]}],"source_ids":[]},{"id":"US-FED-CERULLI","revisions":[{"id":"US-FED-CERULLI","fields":{"Key":"US-FED-CERULLI","Setting":"DoD fire protection","Hazard":"Unread","Instrument (category)":"Fitness-for-duty exam (A)","Initiator; knew of report?":"Agency","Independent assessment":"Cleared","Finding, stage, remedy":"Corrective action denied; affirmed 2020","Fate of hazard":"Unread","Status":"REJECTED (claim)"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":632},"source_urls":[]}],"source_ids":[]},{"id":"US-CA-2017-BICHAI","revisions":[{"id":"US-CA-2017-BICHAI","fields":{"Key":"US-CA-2017-BICHAI","Setting":"Hospital, CA","Hazard":"Patient care advocacy","Instrument (category)":"PACE assessment (A or G — unresolved)","Initiator; knew of report?":"Hospital","Independent assessment":"Found fit","Finding, stage, remedy":"Appellate ruling on pleadings","Fate of hazard":"Unread","Status":"LEAD"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":633},"source_urls":[]}],"source_ids":[]},{"id":"US-NRC-2020-AFRRI","revisions":[{"id":"US-NRC-2020-AFRRI","fields":{"Key":"US-NRC-2020-AFRRI","Setting":"Military research reactor","Hazard":"Nuclear safety, regulatory","Instrument (category)":"IG investigations (not psychiatric)","Initiator; knew of report?":"Management","Independent assessment":"NRC inspections","Finding, stage, remedy":"Chilled environment identified","Fate of hazard":"Open in 2020","Status":"VERIFIED — chilling, not psychiatric"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":634},"source_urls":[]}],"source_ids":[]},{"id":"US-LA-2013-CBI","revisions":[{"id":"US-LA-2013-CBI","fields":{"Key":"US-LA-2013-CBI","Setting":"Nuclear fabrication","Hazard":"Safety concerns","Instrument (category)":"Chilled environment (not psychiatric)","Initiator; knew of report?":"Management","Independent assessment":"NRC","Finding, stage, remedy":"Chilling Effect Letter; confirmatory order","Fate of hazard":"Corrective program","Status":"VERIFIED — chilling, not psychiatric"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":635},"source_urls":[]}],"source_ids":[]},{"id":"UK-2015-FRANCIS","revisions":[{"id":"UK-2015-FRANCIS","fields":{"Key":"UK-2015-FRANCIS","Setting":"NHS England","Hazard":"Patient care","Instrument (category)":"Regulator referral (G)","Initiator; knew of report?":"Employers","Independent assessment":"Review","Finding, stage, remedy":"Recommendations; national guardian","Fate of hazard":"Mixed","Status":"SUPPORTED (pattern)"},"section":"Contrary evidence and limits","batch":19,"provenance":{"document_id":"DOC-815c9747822d7c19","line":636},"source_urls":[]}],"source_ids":[]},{"id":"1983-US-TN-DEFORD","revisions":[{"id":"1983-US-TN-DEFORD","fields":{"Key":"1983-US-TN-DEFORD","Setting":"TVA Sequoyah, QA engineer","Instrument category":"Not psychiatric instrument: depression and hospitalization described as *consequences* of retaliation","Edition 03's account":"Sixth Circuit affirmed retaliatory transfer; remedy remanded","Status here":"Cross-thread; keep out of the instrument count"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":670},"source_urls":[]}],"source_ids":[]},{"id":"2002-US-FED-MEEKER","revisions":[{"id":"2002-US-FED-MEEKER","fields":{"Key":"2002-US-FED-MEEKER","Setting":"USPS (EEOC appeal 01A12137)","Instrument category":"A — required counseling after doctors found him fit","Edition 03's account":"EEOC: requirement lacked job-relatedness or business necessity; no safety-report origin shown","Status here":"Cross-thread; adjacent"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":671},"source_urls":[]}],"source_ids":[]},{"id":"2021-UK-MALIK","revisions":[{"id":"2021-UK-MALIK","fields":{"Key":"2021-UK-MALIK","Setting":"Psychiatric hospital, England (ET 2403141/2018)","Instrument category":"G — medical director's email to the GMC liaison","Edition 03's account":"Detriment for protected disclosures found; automatic unfair dismissal failed; some claims out of time","Status here":"Cross-thread"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":672},"source_urls":[]}],"source_ids":[]},{"id":"1996-US-CT-DELCORE","revisions":[{"id":"1996-US-CT-DELCORE","fields":{"Key":"1996-US-CT-DELCORE","Setting":"CL&P v. Secretary, 85 F.3d 89 (2d Cir.)","Instrument category":"Not psychiatric — settlement terms restricting contact with the NRC","Edition 03's account":"Proposing them was prohibited discrimination","Status here":"Cross-thread; Mechanism 9 analogue"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":673},"source_urls":[]}],"source_ids":[]},{"id":"2015-UK-GMC-HOOPER","revisions":[{"id":"2015-UK-GMC-HOOPER","fields":{"Key":"2015-UK-GMC-HOOPER","Setting":"GMC review","Instrument category":"G — safeguard","Edition 03's account":"Recommends checking whether referred doctors raised safety concerns","Status here":"Cross-thread; implementation unknown"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":674},"source_urls":[]}],"source_ids":[]},{"id":"1994-US-MI-MANDREGER","revisions":[{"id":"1994-US-MI-MANDREGER","fields":{"Key":"1994-US-MI-MANDREGER","Setting":"Detroit Edison, 88-ERA-17","Instrument category":"Mixed","Edition 03's account":"Hostility to NRC reporting found; employer would have removed him anyway","Status here":"Cross-thread; contrary-outcome row"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":675},"source_urls":[]},{"id":"1994-US-MI-MANDREGER","fields":{"Source account":"The actual XIII B 11 section contains Mandreger and Smith. It is not a complete census of psychiatric referrals: other pertinent entries appear elsewhere in the digest.\nMandreger v. Detroit Edison, 88-ERA-17, Secretary 30 March 1994: the digest distinguishes an EAP referral from its consequences. A psychologist found a mental disorder; the worker could not return to the plant, exhausted leave, and later received work with reduced overtime and advancement. Those consequences were adverse action. Engineering role and the precise diagnosis remain unverified; adverse action alone does not establish retaliation.\nSmith v. Esicorp, 93-ERA-16, Secretary 13 March 1996: a compelled doctor visit was adverse but not necessarily retaliatory. The digest reports substantial support for medical attention and a possible safety risk. The worker alleged suppression of scaffolding concerns but had been assigned responsibility for fixing the scaffolding. This is a medical-referral comparison, not evidence of a psychiatric diagnosis or an engineering role.\nSource: EDIG13, XIII B 11.\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG13"},"section":"2. Referral section recovered — two entries, with different consequences","batch":22,"provenance":{"document_id":"DOC-8f03cf5e29f26c05","line":14},"source_urls":["https://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG13"]}],"source_ids":["SRC-b0446ce964ad8b74"]},{"id":"1998-US-GRIFFIN","revisions":[{"id":"1998-US-GRIFFIN","fields":{"Key":"1998-US-GRIFFIN","Setting":"Consolidated Freightways, 97-STA-10/19 (ARB)","Instrument category":"A — psychological scrutiny after a letter to an ALJ and deposition statements","Edition 03's account":"ARB rejected retaliation: independent observations justified the evaluation","Status here":"Cross-thread; key contrary row — litigation documents used in a fitness assessment *without* a retaliation finding"},"section":"Contrary evidence and limits","batch":20,"provenance":{"document_id":"DOC-815c9747822d7c19","line":676},"source_urls":[]}],"source_ids":[]},{"id":"2003-US-NY-PATRICKSON","revisions":[{"id":"2003-US-NY-PATRICKSON","fields":{"Source account":"Primary read: ALJ Recommended Decision and Order, 3 Mar 2005, pp. 1–about 31 of the file: https://www.citizen.org/wp-content/uploads/entergydiscriminationsuit.pdf. ARB final decision, ARB Nos. 05-069 and 05-070, 31 Aug 2007: NOT read (oalj.dol.gov blocks automated access); only DOL digest summaries seen: https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007\n1. Person/role: Carl R. Patrickson, engineer, James A. FitzPatrick plant (NY Power Authority, then Entergy from Nov 2000). Maintenance engineer 1989; field engineer 1991–2000 (monitoring plant modifications); system engineering \"assistant engineer\" from May 2000, monitoring systems for proper operation and maintenance. Engineering role VERIFIED. Safety responsibility is system monitoring and problem reporting; he is not a titled safety engineer.\n2. Concern: emergency service water pump room ventilation: closed fire dampers could let pump motors overheat and fail in a fire. Reported to NRC 1997 (RI-1997-A-0126) and again 31 Mar 2003 (RI-2003-A-0053); also six OSHA-type items reported to the ethics line (Jun 2002) and OSHA (13 Jan 2003). OSHA inspected in Mar 2003.\n3. Label: L3 plus L2. For-cause drug/alcohol test and psychological evaluation via the employer's EAP vendor (EMAX). Employer's descriptors: \"aberrant behavior\", \"out of character\", \"excited emotional state\". The general manager testified: \"I wouldn't say screaming, you know, crazy\". His worst-case rationale: someone \"acting crazed\" might injure someone or tamper with the plant. No diagnosis. Clinical output (L1-adjacent, but not a diagnosis): the EMAX report found \"no significant pathologies\", recommended short-term stress counselling and at least six months' intensified behavioural observation; the report was written by the EMAX vice-president, but a local psychologist, Dr. Joel Richman, saw him.\n4. Initiator and grounds: general manager O'Grady (email 26 Mar), then a 27 Mar meeting of the HR director Zimmerman, O'Grady, engineering director Limpias and site VP Sullivan, plus a call to Entergy Nuclear Northeast in White Plains. Cited policy: AP 11.01 fitness-for-duty program, derived from 10 CFR Part 26. Sullivan said he feared Patrickson \"could do harm to himself\" or equipment, and admitted he knew of no past harm to equipment.\n5. Sequence: 1996–97 disputed evaluations and 1997 NRC report; Jun 2002 ethics-line report; 13 Jan 2003 OSHA letter report; 15 Jan and 25 Feb random tests; 19 Mar OSHA citation signed (minor fine on one item); 24 Mar he shows HR the OSHA findings; 25/26 Mar hallway encounter; 27 Mar email and for-cause referral; leave; 31 Mar second NRC report; 1–3 Apr negative drug test, evaluation, report; 22 Apr his OSHA retaliation complaint; 28 Apr return under agreement; 2003 performance plan; 20 Nov termination.\n6. Contrary and independent evidence: OSHA's regional administrator (17 Jul 2003) found referral legitimate because of \"out of the ordinary behavior\". The HR director described him as quiet and calm, which supports both \"out of character\" and \"no history of instability\". Fewer than five for-cause tests since 2000 at the plant. Patrickson testified he knew no one else kept on 31 days' leave after a negative test or put under six months' observation; Zimmerman said it was the first such programme Entergy had heard of. Patrickson told HR he \"kind of used the NRC thing as a shield\" for a year or two (Zimmerman's memo; Patrickson called \"spiteful\" too strong). O'Grady admitted knowing of the OSHA complaint but testified the ventilation issue was never brought to him; Patrickson said his 2002 \"Short List\" (which included ventilation) was emailed to O'Grady, though he admitted never discussing it with him. Unresolved conflict about who knew what.\n7. Findings: OSHA 17 Jul 2003: no violation. ALJ 3 Mar 2005: finding on the evaluation NOT read. DOL's own ARB digest says the ALJ found the performance-plan meetings were adverse action and found disparate treatment, and that the ARB reversed both and found no pretext for the discharge. That implies the discharge and plan claims were not sustained; it does not say how the evaluation referral was decided. \n8. Consequences and hazard: 31 days' paid leave, return-to-work conditions (stress counselling, six months' observation), then discharge on 20 Nov 2003. Fate of hazard: NRC wrote (28 Apr 2003) that absent new information it had no basis to revise its earlier conclusion that the problems were valid but adequately addressed. Patrickson testified permanent modifications were cancelled. ALJ record shows a 2003 mod list marking two as cancelled. NOT resolved here; no independent check of the 2003 fire analysis.\n9. Griffin test: observed behaviour = a raised-voice hallway exchange and an all-caps email, in a man others call calm. The test is met on the employer's account and contested on his. The independent clinician found nothing pathological. Neither fact settles motive.\n10. Uncertainty / next source: the ARB decision text (05_069.ERAP; try mirror or Westlaw); ALJ conclusions section; whether the evaluation was held adverse; later NRC discrimination findings under allegation RI-2003-A-0053.\nStatus: VERIFIED for facts quoted from the ALJ record. Final adjudicated outcome is against the retaliation claim; whether any reviewing body specifically ruled on the evaluation referral remains unread. The case stays in the register as a contrary/qualified row: independent clinician found no pathology, yet conditions were imposed, and reviewers did not find retaliation."},"section":"3.2 Patrickson v. Entergy Nuclear Operations, 2003-ERA-22 — facts VERIFIED from the ALJ record; final outcome: retaliation NOT established (ARB reversed ALJ; Second Circuit affirmance per addendum, unverified by me)","batch":21,"provenance":{"document_id":"DOC-15b8efeaf6dfd366","line":38},"source_urls":["https://www.citizen.org/wp-content/uploads/entergydiscriminationsuit.pdf.","https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007"]},{"id":"2003-US-NY-PATRICKSON","fields":{"Source account":"Key: 2003-US-NY-PATRICKSON. DOL's 2002–2003 ERA caselist identifies ALJ 2003-ERA-22; recommended decision 3 March 2005; ARB final decision 31 August 2007; and Second Circuit No. 07-4574, 18 December 2008, petition for review denied. The official indexed register confirms the appeal result independently of the earlier addendum. Full circuit decision bytes were not retrieved in this pass. Status: VERIFIED (official register/indexed record) for procedural result; primary judgment text still outstanding. Do not promote this to primary judgment read.\nThe DOL adverse-action digest confirms the Board rejected the ALJ's treatment of performance-plan meetings and found no proven pretext. That does not independently resolve the evaluation referral. The earlier general claim that reviewers found no retaliation must not be restated as a specific finding that the psychological referral was justified.\nSources:\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/CASELISTS/ERALIST8\nhttps://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007"},"section":"1. Patrickson — appeal result confirmed in official register, referral ruling still open","batch":22,"provenance":{"document_id":"DOC-8f03cf5e29f26c05","line":7},"source_urls":["https://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/CASELISTS/ERALIST8","https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007"]}],"source_ids":["SRC-fcf969fd7fb043e5","SRC-c8d0278b4b2aa629","SRC-767c38f2f0a67390"]},{"id":"1996-US-SMITH-ESICORP","revisions":[{"id":"1996-US-SMITH-ESICORP","fields":{"Source account":"The actual XIII B 11 section contains Mandreger and Smith. It is not a complete census of psychiatric referrals: other pertinent entries appear elsewhere in the digest.\nMandreger v. Detroit Edison, 88-ERA-17, Secretary 30 March 1994: the digest distinguishes an EAP referral from its consequences. A psychologist found a mental disorder; the worker could not return to the plant, exhausted leave, and later received work with reduced overtime and advancement. Those consequences were adverse action. Engineering role and the precise diagnosis remain unverified; adverse action alone does not establish retaliation.\nSmith v. Esicorp, 93-ERA-16, Secretary 13 March 1996: a compelled doctor visit was adverse but not necessarily retaliatory. The digest reports substantial support for medical attention and a possible safety risk. The worker alleged suppression of scaffolding concerns but had been assigned responsibility for fixing the scaffolding. This is a medical-referral comparison, not evidence of a psychiatric diagnosis or an engineering role.\nSource: EDIG13, XIII B 11.\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG13"},"section":"2. Referral section recovered — two entries, with different consequences","batch":22,"provenance":{"document_id":"DOC-8f03cf5e29f26c05","line":14},"source_urls":["https://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG13"]}],"source_ids":["SRC-b0446ce964ad8b74"]},{"id":"1991-US-KS-WELLS-85ERA22","revisions":[{"id":"1991-US-KS-WELLS-85ERA22","fields":{"Source account":"Key: 1991-US-KS-WELLS-85ERA22. Official digest SUPPORTS a finding in Wells v. Kansas Gas & Electric, 85-ERA-22, Secretary 21 March 1991. A security-clearance psychologist received inaccurate or unexplained background information already implicated in a successful whistleblower complaint, without context concerning that complaint and reinstatement. The employer used the recommendation to discharge the worker three months after reinstatement. The Secretary found the evaluation invalid in the context of the earlier reinstatement/expungement order and an ERA violation for noncompliance. The digest's editor reports the later appeal was dismissed but explicitly lacks the dismissal order.\nThis connects the 85-ERA-22 proceeding to 83-ERA-12 in the agency's account, strengthening the litigation-family link. It does not independently confirm the person's full identity or engineering qualifications. Keep it outside the engineer count pending role verification.\nSource: EDIG8, VIII B 1 d.\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG8"},"section":"3. Wells — incorrect background material can infect a later evaluation","batch":22,"provenance":{"document_id":"DOC-8f03cf5e29f26c05","line":21},"source_urls":["https://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG8"]}],"source_ids":["SRC-98f9ff767fffe420"]}],"patterns":[{"draft_key":"P01","name":"The report becomes an inquiry into the reporter","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A substantive concern is followed by scrutiny of its author; the original concern needs its own disposition.","supporting_material":["Diaz-Robainas: official retaliation finding","Petitt: affirmed administrative merits finding"],"contrary_material":["Griffin: referral justified on independent evidence","Mandreger: employer prevailed despite evidence of hostility"],"coding_rule":"Code only a documented shift in decision-making subject, with separate dates and asserted reasons. A referral after speech alone does not establish retaliation.","proposed_response":"Keep two linked records: the issue reported and any action concerning the reporter. Neither closes the other automatically.","related_instrument_draft":"Concern Ledger","unknowns":"Fate of the original hazard is often missing from the employment decision. Missing in a reviewed source does not mean no investigation occurred.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P01","source_document_id":"DOC-601bed5c63841332","record_ids":["US-FL-1991-DIAZ-ROBAINAS","US-FED-2015-PETITT","1994-US-MI-MANDREGER","1998-US-GRIFFIN"]},{"draft_key":"P02","name":"Clearance does not end the demand","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A favorable assessment is followed by additional treatment requirements or continued restrictions.","supporting_material":["Meeker: two fitness clearances followed by an unlawful counseling requirement"],"contrary_material":["A new independently documented safety concern can justify a new assessment; no matched positive case has yet been coded."],"coding_rule":"Record assessment scope, date, subsequent evidence and decision-maker. Do not treat clearance as proof that all future restrictions are improper.","proposed_response":"Show the current assessment and the specific new basis for any continuing restriction; include a review date.","related_instrument_draft":"Decision Basis Record","unknowns":"Generalization currently rests on one anchor episode. Need independently justified repeat-assessment comparisons.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P02","source_document_id":"DOC-601bed5c63841332","record_ids":["2002-US-FED-MEEKER"]},{"draft_key":"P03","name":"A disputed record travels","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"An adverse account reaches another authority or context before review or correction is complete.","supporting_material":["Petitt: regulator communication described in the source record"],"contrary_material":["Required safety reporting may legitimately precede a final employment decision; verify governing duties at the event date."],"coding_rule":"Code actual transmission, recipient, purpose, authority and the decision state at transmission. Do not infer disclosure from the mere existence of a record.","proposed_response":"Preserve source status and correction history when information is shared; support correction to authorized prior recipients.","related_instrument_draft":"Source and Correction Receipt","unknowns":"Cross-system correction delivery is not demonstrated by changing the originating record.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P03","source_document_id":"DOC-601bed5c63841332","record_ids":["US-FED-2015-PETITT"]},{"draft_key":"P04","name":"The complaint route depends on the subject of the complaint","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A route for redress depends on records or access controlled by the institution being challenged.","supporting_material":["Arizona IOC reports: recorded retaliation concerns and limits on investigation"],"contrary_material":["A complaint body may be independent yet lack a particular remedy. Absence of release power is not absence of an intake route."],"coding_rule":"Distinguish patient-reported fears, oversight observations and adjudicated retaliation. Identify control over records, access, investigation and remedy separately.","proposed_response":"Make the recipient, available powers, conflicts, escalation options and disposition visible.","related_instrument_draft":"Complaint Route Map","unknowns":"No prevalence estimate or proof that all grievances result in retaliation.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P04","source_document_id":"DOC-601bed5c63841332","record_ids":["2020-AZ-ASH-IOC-RETALIATION","2023-AZ-ASH-IOC-RETALIATION","2023-AZ-DRAZ-ACCESS-SUIT"]},{"draft_key":"P05","name":"A favorable decision arrives before practical repair","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A ruling or clearance is followed by unresolved compensation, reinstatement, costs or correction.","supporting_material":["Denhof: later recertification-cost litigation","Petitt: merits/back pay affirmed, other awards vacated and settlement followed"],"contrary_material":["A timely implemented remedy is a needed comparison; it is not supplied by settlement status alone."],"coding_rule":"Track merits decision, remedy order, delivery and remaining harm separately. Delay alone does not prove intentional obstruction.","proposed_response":"Do not mark an issue repaired when an order merely exists. Record each remedy and evidence of delivery.","related_instrument_draft":"Remedy Delivery Ledger","unknowns":"Settlement confidentiality limits what can be said about actual compensation or terms.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P05","source_document_id":"DOC-601bed5c63841332","record_ids":["2007-US-MI-DENHOF","US-FED-2015-PETITT"]},{"draft_key":"P06","name":"Resolution is offered with a restriction on speaking","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A proposed agreement connects relief with limits on protected reporting or participation.","supporting_material":["Delcore: restrictive settlement proposal held unlawful"],"contrary_material":["Some confidentiality obligations are lawful; jurisdiction, wording, scope and exceptions matter."],"coding_rule":"Code proposed versus signed versus enforced terms separately. No psychiatric intervention is established in Delcore.","proposed_response":"Keep the relief sought separate from requested speech restrictions and show what is being agreed to.","related_instrument_draft":"Agreement Scope Review","unknowns":"This is an adjacent silencing mechanism, not a psychiatric-detention example.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P06","source_document_id":"DOC-601bed5c63841332","record_ids":["1996-US-CT-DELCORE"]},{"draft_key":"P07","name":"An account of harm becomes a claim of group deterrence","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"An individual retaliation event is interpreted as evidence that a wider group stops reporting.","supporting_material":["NRC individual enforcement and separate chilled-environment records provide different evidence streams"],"contrary_material":["NRC reported no evidence of chilling in the cited FPL review; an individual finding does not settle group effect."],"coding_rule":"Code individual harm, expressed fear, actual reporting behavior and group findings separately. A drop in complaints has multiple explanations.","proposed_response":"Evaluate whether people can safely complete and follow up a report; never treat fewer reports as proof of improvement.","related_instrument_draft":"Reporting Experience Review","unknowns":"No reviewed dataset causally joins psychiatric referral to a measured group-wide decline in reporting.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P07","source_document_id":"DOC-601bed5c63841332","record_ids":["US-FL-1991-DIAZ-ROBAINAS","US-NRC-2020-AFRRI"]},{"draft_key":"P08","name":"A correction exists but the older claim still circulates","primary_home":"Pattern","categories":["Boundaries","Design"],"status":"candidate","description":"A later correction does not replace every derivative summary or decision based on the earlier claim.","supporting_material":["Texas SB359 and Arizona HB2744 corrections in the research record","Diaz-Robainas penalty payment resolved after Edition03 marked it unknown"],"contrary_material":["Preserving an old version is legitimate when visibly marked historical and linked to the correction."],"coding_rule":"Identify a concrete stale assertion and its dependency. Research-document examples do not establish the same failure in every product.","proposed_response":"Link corrections to affected claims, patterns and instruments; distinguish corrected source from notified recipient.","related_instrument_draft":"Source and Correction Receipt","unknowns":"This pattern is observed in the compilation process itself; product applicability remains a design hypothesis.","provenance":"Research Record through Batch20; Edition03 and subsequent payment correction","inference_limit":"No diagnosis, motive, incapacity or misconduct inference about a person from a pattern match.","id":"PATTERN-P08","source_document_id":"DOC-601bed5c63841332","record_ids":["TX-2015-SB359-FACILITY-HOLD","AZ-2024-DIRECT-PETITION","US-FL-1991-DIAZ-ROBAINAS"]},{"id":"PATTERN-P22-A","draft_key":"P22-A","name":"Background-record contamination","status":"candidate","description":"A later assessment may reproduce earlier unsupported material when corrections and case context do not reach the assessor.","supporting_material":["Wells: official digest; underlying decision needed"],"contrary_material":["Smith: supported medical intervention alongside an active assignment to correct the reported hazard."],"coding_rule":"Identify the background material, prior correction or expungement, what reached the assessor, and the later decision.","proposed_response":"Keep the concern, assessment grounds, consequences, and each review outcome separately traceable.","unknowns":"Underlying Wells decision and engineering role remain unverified.","source_document_id":"DOC-8f03cf5e29f26c05","record_ids":["1991-US-KS-WELLS-85ERA22"],"inference_limit":"A pattern match does not establish diagnosis, motive or misconduct in an individual case."},{"id":"PATTERN-P22-B","draft_key":"P22-B","name":"Consequences after referral","status":"candidate","description":"Referral counts alone can miss access loss, leave exhaustion, pay effects and return conditions.","supporting_material":["Mandreger: official digest distinguishes the referral from its adverse consequences."],"contrary_material":["Adverse action alone does not establish retaliation; Smith supplies a medical-referral comparison."],"coding_rule":"Code the referral, clinical output, access loss, leave exhaustion, pay effects, return conditions and remedy separately.","proposed_response":"Keep the concern, assessment grounds, consequences, and each review outcome separately traceable.","unknowns":"Precise diagnosis and engineering role remain unverified; underlying decisions needed.","source_document_id":"DOC-8f03cf5e29f26c05","record_ids":["1994-US-MI-MANDREGER","1996-US-SMITH-ESICORP"],"inference_limit":"A pattern match does not establish diagnosis, motive or misconduct in an individual case."},{"id":"PATTERN-P22-C","draft_key":"P22-C","name":"Review-stage specificity","status":"candidate","description":"An appeal concerning performance and discharge must not become a finding about a referral it does not expressly address.","supporting_material":["Patrickson: official register confirms the appeal result; evaluation-specific reasoning still open."],"contrary_material":["A rejected discharge claim does not independently establish that the evaluation referral was justified."],"coding_rule":"Preserve each issue’s outcome at each stage.","proposed_response":"Keep the concern, assessment grounds, consequences, and each review outcome separately traceable.","unknowns":"Patrickson ALJ conclusions, ARB referral treatment and full circuit order remain outstanding.","source_document_id":"DOC-8f03cf5e29f26c05","record_ids":["2003-US-NY-PATRICKSON"],"inference_limit":"A pattern match does not establish diagnosis, motive or misconduct in an individual case."}],"questions":[{"id":"QUESTION-analysis02-01","name":"Shift from issue to reporter","memo":"Anchors: Petitt and Diaz-Robainas. Record the safety issue, decision-maker knowledge, referral proposal and stated grounds separately. Inquiry into fitness is not itself proof of retaliation. Griffin and Mandreger supply contrary outcomes. Personal comparison requires the actual safety report and any actual subsequent referral or threat; presently unspecified.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-02","name":"Decision contemplated before its stated trigger","memo":"Anchor: Petitt's record, as summarized in the supplied Batch19, contains proposed fitness scrutiny before the meeting later advanced as justification. This is more informative than timing alone. Obtain contemporaneous emails or notes; distinguish discussion from authorization and execution.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-03","name":"Grounds that change over time","memo":"Compare first explanation, later explanation, clinical assessment and tribunal findings. Changed grounds can reflect new evidence or pretext; preserve both possibilities. A timeline must record when each fact became known, not merely when later accounts were written.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-04","name":"Independent disagreement","memo":"Anchors: Petitt and Meeker. Independent clearances can contradict an asserted need for restriction, but scope, date and new evidence matter. Do not count multiple reports based on one interview as independent corroboration.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-05","name":"Order or threat without examination","memo":"Diaz-Robainas concerns a psychological evaluation order and dismissal for refusal; an examination did not occur. The coercive effect of an employment condition must remain distinct from physical detention. Track threatened, ordered, attempted and performed actions separately.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-06","name":"Evaluation becomes restriction or repeated demand","memo":"Meeker illustrates counseling required after fitness clearances, with an unlawful requirement finding. Preserve the difference between voluntary care, a condition of work, and involuntary admission. One adverse outcome does not establish every follow-up demand was improper.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-07","name":"Record transmitted to another authority","memo":"Petitt provides an account of communication to a regulator. Identify exactly what was transmitted, its status, recipient, purpose and legal basis. An inaccurate record remaining at the original institution differs from an actual downstream disclosure. Correcting the first copy does not prove the recipient received a correction.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-08","name":"Redress controlled by the institution challenged","memo":"Arizona oversight material records concerns and limits on investigation. COPR and county advocates have functions even where they cannot order release. Record who receives a grievance, who investigates, who controls evidence, who decides, and available review. Do not turn an unsubstantiated grievance into either proof of misconduct or proof that nothing happened.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-09","name":"The professional who objects is targeted","memo":"NEW: Murphy v. U.S. Department of Veterans Affairs, D. Maine,23Aug2013. Nurse Amber Murphy alleged retaliation after objecting to a patient's involuntary commitment. The court denied dismissal/summary judgment at that stage and expressly distinguished pleaded facts from the defendants' opposing account. This was not a final liability finding and not a finding that Murphy was hospitalized. Later disposition remains unlocated. It expands the inquiry to the treatment of staff who challenge an intervention affecting someone else. Source, pages1–4 and concluding order: https://www.govinfo.gov/content/pkg/USCOURTS-med-1_12-cv-00379/pdf/USCOURTS-med-1_12-cv-00379-0.pdf","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-10","name":"A procedural barrier is treated as a universal absence of remedy","memo":"NEW: Rawson v. Recovery Innovations,9thCir.2020, reversed summary judgment on state-action grounds. Under those facts, a private psychiatric provider acted under color of state law. Wrongful detention, forced medication and misleading the court were the underlying allegations, not all finally proved by that appellate ruling. This qualifies any blanket claim that private facilities cannot face federal civil-rights claims. No safety-whistleblowing trigger is established. Later merits outcome remains unlocated. Source: https://law.justia.com/cases/federal/appellate-courts/ca9/19-35520/19-35520-2020-09-09.html","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-11","name":"Merits decision precedes practical repair","memo":"Denhof, Petitt and Diaz-Robainas require separate remedy histories. The NRC's1997 record confirms the Diaz-Robainas $100,000 penalty was paid3Dec1996. That payment is not evidence of the employee's confidential settlement compensation or resolution of the original technical concern. Source: https://www.govinfo.gov/content/pkg/FR-1997-09-12/pdf/97-24220.pdf (footnote5)","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-12","name":"Resolution adds restrictions on speech","memo":"Delcore is an adjacent case about proposed settlement restrictions; not psychiatric detention. The actual proposed wording and governing context matter. Confidentiality and unlawful suppression cannot be equated without analysis.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-13","name":"Prior labels affect later credibility","memo":"The record raises this concern, but there is no general rule that hospitalization makes testimony inadmissible or incredible. The Robinson witness case involved mother-initiated commitment and particular credibility evidence. Judicial findings, evidentiary relevance and strategic misuse are different questions.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-14","name":"Complaint persistence is interpreted as incapacity","memo":"Richards, Washburn and the querulous-complainant literature need their corrections attached. Persistence alone does not establish incapacity. Richards included appellate reversal and an agreed examination. Washburn involved clinical material, not filing volume alone. No pattern classifier should infer mental condition from report count, wording, repetition or frustration.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-15","name":"Fear alters reporting","memo":"Separate stated fear; withholding information; delayed reporting; actual reporting decline; and an official group-level chilling finding. It does not establish that he stopped reporting, nor group-wide effects. Historical individual retaliation findings and NRC group-environment records are separate evidence streams. Lower complaint numbers could reflect improvement, loss of access, fear or measurement changes.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-16","name":"The original issue disappears from the available decision","memo":"Employment litigation may decide retaliation without deciding the technical hazard. Mark 'not stated in reviewed source,' not 'ignored by everyone.' Retrieve the safety investigation separately. In Petitt, the reported commute-time policy change needs the FAA source; a secondary report does not resolve every safety allegation.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-17","name":"Multiple summaries appear to corroborate one account","memo":"Claude, this thread, news coverage and a digest may all derive from the same judgment. Track source lineage before counting agreement. Independent corroboration requires a genuinely separate evidentiary basis, not another author or model.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"},{"id":"QUESTION-analysis02-18","name":"Correction does not reach the working conclusion","memo":"Texas2015 SB359 was vetoed; Arizona2024 enacted text differed from introduced text; the penalty payment was initially missed. Keep a dependency list from corrected claim to case summary, pattern and proposed instrument. Never base personal advice on a historical draft with superseded claims.","status":"candidate","source_document_id":"DOC-8a55108039e0986b"}],"mechanisms":[{"id":"MECHANISM-1","name":"Credibility displacement","fields":{"Mechanism":"1. Credibility displacement","How it operates":"A psychiatric record or label is used so that what the person says is heard as symptom rather than testimony","Strongest instances":"Ellsberg/Fielding (1971); Martha Mitchell (1972); military \"personality disorder\" discharges (HRW 2016)","Evidence type":"Conviction and plea (Ellsberg); IG finding (military); interpretation (Mitchell)","Purpose or effect shown":"PURPOSE shown for Ellsberg; EFFECT shown for military discharges; Mitchell purpose inferred"},"source_document_id":"DOC-815c9747822d7c19","line":533,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-2","name":"Removal at the moment of speech","fields":{"Mechanism":"2. Removal at the moment of speech","How it operates":"Detention coincides with disclosure, complaint, or protest, removing the speaker from the scene","Strongest instances":"Schoolcraft (hours after his disclosures became known); Chinese petitioners confined around sensitive dates; Soviet pre-trial psychiatric transfer","Evidence type":"Hospital records and settlement (Schoolcraft); NGO case files (China); Soviet admission (1989)","Purpose or effect shown":"PURPOSE shown for USSR; ALLEGATION with settlement for Schoolcraft"},"source_document_id":"DOC-815c9747822d7c19","line":534,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-3","name":"The procedural shadow","fields":{"Mechanism":"3. The procedural shadow","How it operates":"A low-threshold, no-pre-hearing hold protected by immunity makes the downside of speaking asymmetric; the threat does the work without detention","Strongest instances":"§ 5150 structure (§ 5278 immunity; Julian 2017); federal fitness-for-duty exams (MSPB 1.6%→6.1%); 36% of consumers citing fear of coerced treatment as a barrier to care (Swartz et al. 2003)","Evidence type":"CHILL-RESEARCH (MSPB; Swartz); CHILL-OFFICIAL (1978 House subcommittee); CHILL-INTERPRETATION for § 5150 specifically","Purpose or effect shown":"EFFECT shown by survey; purpose shown for FFD exams in 1978 finding"},"source_document_id":"DOC-815c9747822d7c19","line":535,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-4","name":"Durable record stigma","fields":{"Mechanism":"4. Durable record stigma","How it operates":"Collateral consequences attach automatically (firearm prohibition under Welf. & Inst. Code § 8103; discharge codes; employment), so a single hold deters future assertion of rights","Strongest instances":"§ 8103 five-year prohibition after a 5150 admission; HRW *Booted* on benefits ineligibility","Evidence type":"Statute (§ 8103); NGO documentation","Purpose or effect shown":"EFFECT shown; purpose not required for the deterrent to operate"},"source_document_id":"DOC-815c9747822d7c19","line":536,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-5","name":"Diagnostic elasticity","fields":{"Mechanism":"5. Diagnostic elasticity","How it operates":"Categories wide enough to absorb dissent, grievance, or non-conformity","Strongest instances":"\"sluggish schizophrenia\"; \"protest psychosis\"; drapetomania; \"adjustment disorder\" after assault","Evidence type":"Historical and archival scholarship (Metzl; van Voren); Soviet admission","Purpose or effect shown":"PURPOSE shown for USSR; effect shown elsewhere"},"source_document_id":"DOC-815c9747822d7c19","line":537,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-6","name":"Private-party initiation","fields":{"Mechanism":"6. Private-party initiation","How it operates":"Family members, employers, or conservators trigger or sustain the process; the state supplies the force","Strongest instances":"Packard (1860); Spears allegations (2008–2021); Donaldson (father's petition, 1957)","Evidence type":"Jury verdict (Packard); Supreme Court finding (Donaldson); ALLEGATION only (Spears)","Purpose or effect shown":"Mixed; shows the channel, not a general pattern"},"source_document_id":"DOC-815c9747822d7c19","line":538,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-7","name":"Welfare framing as pretext","fields":{"Mechanism":"7. Welfare framing as pretext","How it operates":"\"Concern for the person's safety\" supplies a non-reviewable justification; the person's objection is read as symptomatic","Strongest instances":"Schoolcraft (police said he needed medical help); Raub (TDO petition empty of facts); Julian (investigating an assault on her)","Evidence type":"Judicial finding of deficient petition (Raub); hospital record (Schoolcraft)","Purpose or effect shown":"EFFECT shown; purpose contested"},"source_document_id":"DOC-815c9747822d7c19","line":539,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-8","name":"Post-detention discounting","fields":{"Mechanism":"8. Post-detention discounting","How it operates":"After release, the person's prior and later statements are weighed against the fact of the hold","Strongest instances":"\"Martha Mitchell effect\" (Maher 1988); survivors' accounts in HRW reports; Spears' testimony met with a request to investigate its accuracy","Evidence type":"Clinical literature naming the phenomenon; NGO testimony","Purpose or effect shown":"CHILL-TESTIMONY; purpose not shown"},"source_document_id":"DOC-815c9747822d7c19","line":540,"standing":"Original synthesis; examine later corrections before relying on its formulation."},{"id":"MECHANISM-9","name":"Silencing the complaint channel itself","fields":{"Source account":"**Batch 2–3 update to the mechanisms.** The worldwide pass strengthens four of the eight and adds one. Mechanism 2 (removal at the moment of speech) now has purpose-evidence outside the USSR: Saman Yasin's hospitalization two days after his prison recording about torture (Iran, 2023), the GDR practice of admitting psychiatric patients around state holidays as potential disruptors (Süß, from Stasi files), and Chinese petitioners confined before sensitive dates — the same timing logic in three unrelated systems. Mechanism 1 (credibility displacement) gains a judicial form: Iranian courts entering mental-illness \"diagnoses\" as sanctions against unveiled actresses (2023), and Vallejo-Nágera's 1938–39 studies supplying a scientific vocabulary for discounting Republican women. Mechanism 3 (procedural shadow) gains US jury findings that fitness-for-duty exams were ordered as retaliation for testimony (Denhof, Michigan 2007; Blake, Maryland 2011) — the first adjudicated retaliatory-purpose findings in the record. Mechanism 6 (private-party initiation) gains a constitutional court's statement that guardian–psychiatrist collusion \"often occurred\" (Korea 2016), Japan's founding Sōma inheritance case (1883), and the Duplessis fiscal motive. The new ninth mechanism is **silencing the complaint channel itself**: Lake Alice children shocked for complaining or running away, with professional bodies and ministries failing to act on complaints for 40 years (Royal Commission 2022), and Duplessis survivors' testimony met with demands for case-by-case proof — detention that discredits the person's later account of the detention."},"source_document_id":"DOC-815c9747822d7c19","line":544,"standing":"Original synthesis; interpretation and evidence must remain distinct."}],"corrections":[{"id":"CORRECTION-0013","text":"Batch 4 (6 Oct 2026) opens Romania, Cuba, Australia and South Africa, adding a second \"complaint channel\" finding (Chelmsford) and a US federal jury finding on Cuban electroshock \\[corrected, Batch 18/D03: the 2002 conviction was for unlawful procurement of naturalization; what the jury found about electroshock is unestablished\\] torture (Mederos, 2002).","document_id":"DOC-815c9747822d7c19","line":13,"record_ids":[]},{"id":"CORRECTION-0017","text":"Batch 6 (6 Oct 2026) adds Turkey (forensic medicine used to keep prisoners in, not put them in), India (custodial neglect under court and NHRC monitoring), and the 22-country comparative data set that serves as the comparison set for \\[corrected, Batch 18/D06: observational, measures incidence not wrongful detention; \"control group\" withdrawn\\] the whole record: legal safeguards \\[withdrawn as a general claim, Batch 20/A04: an incidence comparison cannot show safeguards fail\\] do not predict detention rates.","document_id":"DOC-815c9747822d7c19","line":17,"record_ids":[]},{"id":"CORRECTION-0031","text":"Batch 13 (7 Oct 2026) begins the US state sweep at Arizona under the method: channel 1 (Title 36 procedure names in case law and session laws). Arizona's initiation rules are the loosest yet \\[corrected, Batch 18/D02: ranking withdrawn; the enacted 2024 law kept screening-agency filing\\] mapped in the United States and were amended (applicant notice and reasons; not loosened — corrected Batch 18/D02) in 2024.","document_id":"DOC-815c9747822d7c19","line":31,"record_ids":[]},{"id":"CORRECTION-0035","text":"Batch 15 (7 Oct 2026) opens Texas under channel 1 (Chapter 573 instrument names and session laws) and channel 2 (a municipal police-oversight complaint file). Texas shows a different design from Arizona: initiation is officer- and facility-led, and the legislature has explicitly carved the facility hold \\[corrected, Batch 18/D01: SB 359 was vetoed 2 Jun 2015; this describes a proposal, not law\\] out of the firearm-record consequence.","document_id":"DOC-815c9747822d7c19","line":35,"record_ids":[]},{"id":"CORRECTION-0103","text":"**What § 5150 is and is not.** Section 5150 authorizes a peace officer or county-designated professional, on probable cause, to take a person into custody for up to 72 hours of evaluation when, as a result of a mental disorder, the person is a danger to others, to self, or gravely disabled. It is not a commitment, a competency examination, a conservatorship, or a voluntary assessment. Its design features — low threshold, no pre-detention hearing, statutory immunity for those acting under it (§ 5278), and a firearm prohibition that attaches to qualifying admissions \\[corrected, Batch 18/E01: § 8103(f) requires custody, assessment and admission as a danger to self or others — not every hold\\] (§ 8103) — are exactly the features that make it both a workable emergency tool and a credible threat. Volume is large: DHCS reported roughly 131,000–136,000 adult 72-hour admissions a year in fiscal 2016–17 and 2017–18 ([DHCS FY17-18 report](https://www.dhcs.ca.gov/Documents/CSD_YV/MHSA/IDR/FY17-18-IDR-Report.pdf); column reading flagged for re-check).","document_id":"DOC-815c9747822d7c19","line":103,"record_ids":[]},{"id":"CORRECTION-0134","text":"| 1981 | California (9th Cir.) | Doe v. Gallinot: probable-cause hearing required after emergency detention, no later than day seven \\[corrected, Batch 18/E02\\] | 5250 | JUDICIAL FINDING; leads to certification review hearings (§ 5256) | SUPPORTED | 657 F.2d 1017 |","document_id":"DOC-815c9747822d7c19","line":134,"record_ids":[]},{"id":"CORRECTION-0141","text":"| 16–23 Aug 2012 | Virginia (US) | Marine veteran Brandon Raub detained under a temporary detention order over Facebook posts; special justice orders 30 days; circuit judge dismisses petition as \"devoid of any factual allegations\" | NON-CA-HOLD (Va. TDO) | JUDICIAL FINDING on procedural deficiency, not on motive; later civil suit REJECTED: 4th Cir. affirmed for Campbell 29 Apr 2015 (no First Amendment causation; qualified immunity), cert. denied 16 Nov 2015 \\[corrected, Batch 18/E03\\] | VERIFIED (secondary) | [Rutherford Institute](https://www.rutherford.org/publications_resources/on_the_front_lines/victory_circuit_court_orders_brandon_raub_released_dismisses_case_against_m); [ABC News](https://abcnews.go.com/blogs/politics/2012/08/former-marine-detained-after-alleged-facebook-threats/) |","document_id":"DOC-815c9747822d7c19","line":141,"record_ids":[]},{"id":"CORRECTION-0193","text":"| 2012-US-VA-RAUB | Virginia | Temporary detention order over political Facebook posts; circuit judge dismissed petition as lacking factual allegations | JUDICIAL FINDING (procedural); Raub's civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\] | Speech-triggered hold | Virginia TDO procedure includes a special-justice hearing within days — a step LPS lacks at the 72-hour stage |","document_id":"DOC-815c9747822d7c19","line":193,"record_ids":["2012-US-VA-RAUB"]},{"id":"CORRECTION-0216","text":"| 2012-US-VA-RAUB | Virginia, 2012 | Brandon Raub; Chesterfield police; FBI; John Randolph Medical Center; Salem VA facility | Virginia temporary detention order | Detained over political and lyric posts; held 7 days | JUDICIAL FINDING: petition \"devoid of any factual allegations\"; civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\] | VERIFIED (secondary) |","document_id":"DOC-815c9747822d7c19","line":216,"record_ids":["2012-US-VA-RAUB"]},{"id":"CORRECTION-0315","text":"| 1963-CU-MAZORRA | Cuba, 1963–1980s | State Security interrogation (Villa Marista) followed by forensic-ward confinement at Havana Psychiatric Hospital (Mazorra) and Gustavo Machín (Santiago); electroshock | Brown & Lago documented 27–31 dissidents (sources differ) diagnosed with conditions such as \"apathy toward socialism\"; nurse Heriberto Mederos named by ten victims | Book-length investigation (Freedom House, 1991); JUDICIAL FINDING: a US federal jury convicted Mederos \\[corrected, Batch 18/D03: the offence was unlawful procurement of naturalization through false statements about persecution and Party membership; he died before sentencing; the verdict's necessary findings on electroshock are a LEAD — original wording follows\\] in 2002 of lying to immigration officials by denying he administered electroshock to political prisoners ([Cubanet](https://www.cubanet.org/htdocs/CNews/y02/ago02/09e6.htm); [Seattle Times, 1992](https://archive.seattletimes.com/archive/19920506/1490272/electroshock-torture-in-cuba-alleged----ex-political-prisoners-say-they-were-subjected-to-it); [JAAPL review](https://jaapl.org/content/20/2/237)) | Amnesty's researcher in 1992: no \"generalized practice\" found, though pressure on certain prisoners \"could have been used\"; Cuban authorities refused APA access to Mazorra | VERIFIED with DISPUTED scale |","document_id":"DOC-815c9747822d7c19","line":315,"record_ids":["1963-CU-MAZORRA"]},{"id":"CORRECTION-0391","text":"*Reading across the channel-1 yield.* Four California holds reached a federal appellate court; in three the question of motive was never reached because probable cause was found; in one it was reached at trial and rejected on officer credibility. Combined with *Julian* (immunity, state action) and *Nieves* (doctrine), the California record now shows **\\[corrected, Batch 18/D05: overstated — Gonzalez v. Trevino (2024) narrows Nieves; the door is narrow, not shut\\] every available legal door to a retaliatory-hold finding closes before or at the motive question**. That is itself a Mechanism 3 finding: the procedural shadow is not only on the detained person but on the courts' capacity to see the pattern.","document_id":"DOC-815c9747822d7c19","line":391,"record_ids":[]},{"id":"CORRECTION-0397","text":"| CA-COPR-STRUCTURE | Each county has a Patients' Rights Advocate (W&I § 5500 ff.) with \"no direct or indirect clinical\" role, who investigates complaints in LPS facilities and reports Denial of Rights and ECT data upward to the California Office of Patients' Rights (COPR), operated under DHCS contract | A complaint path that exists at every LPS facility and is explained in county brochures ([San Bernardino DBH brochure](https://www.sbcounty.gov/uploads/DBH/2023/10/Patients%27%20Rights%20Brochure.pdf)) | The advocate's jurisdiction begins inside the facility; the § 5150 application itself — the moment of initiation — is outside it. A person whose grievance is *why they were brought in* has no designated recipient \\[corrected, Batch 18/D04: COPR handles intake, referral and county appeals but cannot change legal status; whether initiation complaints are accepted is untested\\] for that complaint | VERIFIED (structure) |","document_id":"DOC-815c9747822d7c19","line":397,"record_ids":["CA-COPR-STRUCTURE"]},{"id":"CORRECTION-0401","text":"*Channel-9 reading.* The California complaint channel is real, staffed and lawful, and its outputs are designed to count rights denied *during* detention. Nothing in the reporting architecture can register a detention that was wrongly *begun*. This is the structural reason Batch 11's finding — every legal door closes before motive — is mirrored on the administrative side: there is \\[withdrawn, Batch 20/A04: overstated from the forms reviewed; county intake and appeal records untested\\] no form on which a retaliatory hold could be recorded even if one occurred. The parallel thread should treat the absence of California retaliatory-hold findings as an artifact of instrument design, not as evidence of absence.","document_id":"DOC-815c9747822d7c19","line":401,"record_ids":[]},{"id":"CORRECTION-0408","text":"| AZ-2024-DIRECT-PETITION | 2024 session law (56th Leg., 2nd Reg. Sess., ch. 152, HB 2744) added a \"\\[SUPERSEDED, Batch 18/D02: this describes the introduced bill HB2744P; the enacted chapter keeps § 36-523(C)(2), filing only by the screening agency, and adds § 36-520(J) applicant notice of denial and reasons. Original wording:\\] direct petition for court-ordered evaluation\": if the screening agency declines to file, the applicant may petition the court directly; it also gives guardians and agents notice and standing in treatment proceedings | Session law ([azleg.gov](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf); [bill text](https://www.azleg.gov/legtext/56leg/2R/bills/HB2744P.pdf)) | — | Removes the \\[SUPERSEDED, Batch 18/D02 — the enacted law does not remove the gate; ranking withdrawn. Original wording:\\] clinical filter between a private complainant and the court; the first US jurisdiction in the record to *weaken* the professional gate in the 2020s. Arizona now sits beside Korea pre-2016 and the loi de 1838 in initiation design | VERIFIED |","document_id":"DOC-815c9747822d7c19","line":408,"record_ids":["AZ-2024-DIRECT-PETITION"]},{"id":"CORRECTION-0435","text":"| TX-2015-SB359-FACILITY-HOLD | 2015 SB 359 \\[SUPERSEDED, Batch 18/D01: VETOED by Governor Abbott 2 Jun 2015; the text below describes the engrossed bill, never law. Original wording:\\] (84R) added § 573.005: hospitals, emergency departments and freestanding ERs may detain a person up to four hours without an officer or court order when a physician believes there is no time to file; a notice of detention goes in the medical record; subsection (h): such detention \"is not considered involuntary psychiatric hospitalization\" for the handgun-license disqualification in Government Code § 411.172(e) | Session law ([SB 359 engrossed](https://www.legis.state.tx.us/tlodocs/84R/billtext/doc/SB00359S.doc)) | — | A legislature designing an emergency hold *so that it leaves no firearm-record trace* — Mechanism 4 addressed by statute, in the opposite direction from California's § 8103 | VERIFIED |","document_id":"DOC-815c9747822d7c19","line":435,"record_ids":["TX-2015-SB359-FACILITY-HOLD"]},{"id":"CORRECTION-0446","text":"| 2005-US-3D-CIR-RICHARDS \\[re-keyed 2006-US-VI-RICHARDS, Batch 20/A01: opinion filed 23 Jan 2006, appeal from the District Court of the Virgin Islands\\] | US, 3d Cir. (non-precedential, 2005) | 1-reverse | COMPETENCY-EXAM (civil, Rule 17(c)); adversary-initiated | A pro se attorney-plaintiff; the defendant university \"suggested the District Court consider\" her competency; the magistrate judge ordered a psychiatrist to address it and appointed a guardian, stripping her of control of her own case; the Third Circuit took jurisdiction on the ground that denial of the right to proceed pro se \"injures dignity\" | JUDICIAL (interlocutory review granted) ([*Richards v. Duke University*, 3d Cir. 05-1170](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf)) | VERIFIED (opinion); **first row in the record where the opposing party in civil litigation initiated the psychiatric inquiry** |","document_id":"DOC-815c9747822d7c19","line":446,"record_ids":["2005-US-3D-CIR-RICHARDS"]},{"id":"CORRECTION-0454","text":"1. **Crowds get criminal law \\[WITHDRAWN as a rule, Batch 20/A04: the absence of holds in the protest searches run is a search result, not a pattern about crowds or individuals; kept here for provenance\\]; individuals get psychiatry.** The reverse search on US protest activists 2015–2026 returned arrests, charges and civil-rights settlements (Philadelphia $9.25M; Akron; St. Paul) and not one psychiatric hold. Every US psychiatric instance in the record is a single person embedded in an institution that owes them a duty of care — employer, department, family, court, hospital, jail. The welfare pretext (Mechanism 7) needs a custodial relationship to attach to. This predicts where to look: not protest records, but HR files, court dockets, guardianship registers, and institutional grievance logs.","document_id":"DOC-815c9747822d7c19","line":454,"record_ids":[]},{"id":"CORRECTION-0455","text":"2. **In US civil courts the querulous marker runs through procedure, not diagnosis.** Rule 17(c) competency inquiries, guardian-ad-litem appointments, and vexatious-litigant orders perform the function ICD-10 F22.8 performs in Kazakhstan: the act of complaining becomes the evidence that the complainant cannot be heard. *Richards \\[corrected, Batch 20/A01, opinion re-read: Duke suggested the Rule 17(c) inquiry; Richards agreed to the psychiatric evaluation; the magistrate asked whether the text of her complaint showed \"delusional psychosis\"; the Third Circuit vacated the guardian appointment and held her competent to proceed pro se — a capacity-procedure case with appellate correction, not a retaliation finding\\]* adds that the adversary can start it; *James* adds that a prior adjudication can close the courthouse outright; the Maryland \\[Washburn v. McCarthy, 2021, per Edition 03/A03: clinical evaluations and other evidence supported the capacity decision; filing volume was not the whole basis — primary text not reopened in Batch 20\\] case adds that the costs can be charged to the person's own estate. Channel 6 now includes, for every US jurisdiction, the state's vexatious-litigant statute and its guardian-ad-litem rule as instruments to search.","document_id":"DOC-815c9747822d7c19","line":455,"record_ids":[]},{"id":"CORRECTION-0479","text":"2. **The law converts a hospitalization into impeachment on its own.** Federal evidence doctrine treats a witness's \"insanity or mental abnormality,\" at the time of observing or of testifying, as provable on credibility. That means a hold placed before testimony has a guaranteed second effect without anyone intending it: even if the witness is released in time, the record is admissible against what they say. Mechanism 1 (credibility displacement) is therefore built into the rules of evidence, and the parallel thread should treat every pre-testimony hold as a two-instrument \\[WITHDRAWN, Batch 20/A04: a hospitalization does not automatically make a record admissible or a witness incredible; Robinson turned on its facts and Hargrove upheld refusal of records\\] event.","document_id":"DOC-815c9747822d7c19","line":479,"record_ids":[]},{"id":"CORRECTION-0486","text":"| D02 — AZ-2024-DIRECT-PETITION | HB 2744 (2024 ch. 152) created a \"direct petition\" letting an applicant go to court when the screening agency declines | The enacted chapter adds § 36-504.01 (guardian/agent rights), a new § 36-520(J) requiring the agency to notify the applicant of a denial and, on request, give reasons, and § 36-523(C)(2): the petition \"may be filed only by the screening agency.\" No direct petition exists in the enacted text; the heading I relied on was in the *introduced* bill (HB2744P) and was dropped | Chapter 152 text opened in full this batch ([azleg.gov](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf)) | Row retitled **AZ-2024-CH152-APPLICANT-NOTICE**; claim reduced to: applicants gain notice of denial and reasons; the clinical gate stands. The \"loosest US initiation design\" ranking and the comparison to Korea pre-2016 and the loi de 1838 are **withdrawn**. Batch 13's lesson for the method: an introduced bill is not a session law — version status must be recorded on every statute row |","document_id":"DOC-815c9747822d7c19","line":486,"record_ids":["AZ-2024-DIRECT-PETITION"]},{"id":"CORRECTION-0491","text":"| D06 — 2019-EU-22-COUNTRY | Called the Sheridan Rains study \"the control group for the whole record\" and said it shows safeguards do not govern coercion | It is an observational cross-national comparison of detention *incidence*; it measures neither wrongful nor retaliatory detention and cannot show that safeguards fail | Accepted | \"Control group\" language withdrawn; the row now says only that coded legal features were not associated with incidence across 22 countries, with definitional and implementation differences unexamined |","document_id":"DOC-815c9747822d7c19","line":491,"record_ids":["2019-EU-22-COUNTRY"]},{"id":"CORRECTION-0603","text":"| Implementation | Press reports say Delta sent the decision to pilots and the case settled in late 2022 with $confidential terms \\[corrected, Batch 20: AP, 21 Oct 2022 — settlement approved by ALJ Morris that day; terms confidential; her law firm said they were \"consistent with\" the 2020 ruling; no amount established\\]. Remand decision and settlement terms not seen: **LEAD**. |","document_id":"DOC-815c9747822d7c19","line":603,"record_ids":[]},{"id":"CORRECTION-0606","text":"*Correction carried forward (C19-01).* Summaries in this record and elsewhere that describe a sustained \"$500,000 award\" are superseded: the ARB vacated it. Any $payment \\[corrected, Batch 20: the settlement amount is confidential and not established\\] is reported as a settlement, which establishes no liability beyond the affirmed findings. The affirmed findings stand on their own.","document_id":"DOC-815c9747822d7c19","line":606,"record_ids":[]},{"id":"CORRECTION-0653","text":"| A01 Richards | Filed 23 Jan 2006; Virgin Islands; exam agreed; guardian vacated | [Opinion](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf) read in full: confirmed. Adds that the magistrate asked whether the *text of the complaint* showed \"delusional psychosis\", and the court held a guardian protects the incompetent person, \"not the defendants\" | Row re-keyed 2006-US-VI-RICHARDS; Batch 16 pattern 2 amended |","document_id":"DOC-815c9747822d7c19","line":653,"record_ids":[]},{"id":"CORRECTION-0654","text":"| A02 Tenth Circuit witness | *United States v. Robinson*, 583 F.3d 1265; mother-initiated; Hargrove contrary | [Opinion](https://www.ca10.uscourts.gov/sites/ca10/files/opinions/01018295738.pdf) excerpt confirms the mother committed the informant believing him suicidal | Row identified; \"two-instrument\" pattern withdrawn |","document_id":"DOC-815c9747822d7c19","line":654,"record_ids":[]},{"id":"CORRECTION-0656","text":"| A04 universal claims | Withdraw five general claims | Agreed: each rests on bounded searches | \"Crowds/individuals\", \"no form\", \"two-instrument\", \"safeguards do not\" marked withdrawn; \"every door\" was already corrected in Batch 18 |","document_id":"DOC-815c9747822d7c19","line":656,"record_ids":[]}],"visibility":"public","documents":[{"id":"DOC-815c9747822d7c19","title":"Psychiatric Detention, Silencing, and Chilling Effects — Research Record","source_sha256":"4a898b1ac04bfec42e87fee38d90841e63ff883f3b56ebac15402054fe345c3e","text":"# Psychiatric Detention, Silencing, and Chilling Effects — Research Record\n\n\n\n## Batch log and conventions\n\nBatch 1 (6 Oct 2026) lays the spine: the historical overview, landmark timeline entries, a first California register, a first international register, the mechanism synthesis, reforms, contrary evidence, and the bibliography. Later batches deepen decade by decade. Nothing here claims completeness; every coverage gap is named in section 9.\n\nBatch 2 (6 Oct 2026) widens the mission from California to a worldwide record: a US national and state register, a worldwide register by region with local-language leads, and a geographic coverage index. Batch 1 content is preserved unchanged; California becomes one chapter.\n\nBatch 3 (6 Oct 2026) opens the Batch 2 leads: a national US emergency-hold framework and six US state retaliation cases with jury findings; local-language passes for Korea, Japan, Spain and East Germany; Iran and the post-Soviet states; and a mechanism update. Coverage index status changes are listed under the index table.\n\nBatch 4 (6 Oct 2026) opens Romania, Cuba, Australia and South Africa, adding a second \"complaint channel\" finding (Chelmsford) and a US federal jury finding on Cuban electroshock \\[corrected, Batch 18/D03: the 2002 conviction was for unlawful procurement of naturalization; what the jury found about electroshock is unestablished\\] torture (Mederos, 2002).\n\nBatch 5 (6 Oct 2026) adds the Southern Cone — Argentina, Chile and Uruguay — where the documented pattern is inverted: the dictatorships targeted the mental-health professions and used psychiatric labels inside prisons rather than confining dissidents in hospitals.\n\nBatch 6 (6 Oct 2026) adds Turkey (forensic medicine used to keep prisoners in, not put them in), India (custodial neglect under court and NHRC monitoring), and the 22-country comparative data set that serves as the comparison set for \\[corrected, Batch 18/D06: observational, measures incidence not wrongful detention; \"control group\" withdrawn\\] the whole record: legal safeguards \\[withdrawn as a general claim, Batch 20/A04: an incidence comparison cannot show safeguards fail\\] do not predict detention rates.\n\nBatch 7 (6 Oct 2026) resolves the Goldwater lead to VERIFIED from the American Journal of Psychiatry and JAAPL accounts and records it as the clearest US case of diagnostic discrediting adjudicated as actual malice.\n\nBatch 8 (6 Oct 2026) adds Puerto Rico (first US territory researched), Belarus (UN-documented 33–37 punitive psychiatric sentences since 2020), Kazakhstan's Mukhortova case (a lawyer confined after complaining about a legislator, with a court citing her \"litigious\" activity as a ground), and the named diagnostic category that underwrites that logic: querulous paranoia (ICD-10 F22.8).\n\nBatch 9 (6 Oct 2026) verifies France's Claudel case against the Musée Camille Claudel chronology and the 1838 law's \"placement volontaire\" mechanism, closing the last of the Batch 2 European leads except Italy.\n\nBatch 10 (7 Oct 2026) is the first run under the ten-channel method, applied to California: channel 3 (survivor archives) surfaced the pre-LPS Frank commitment and the Madness Network News / NAPA / Measure T line; channel 6 (adjacent instruments) surfaced jail suicide-watch findings, including a federal DOJ finding against Alameda County's John George hospital that upgrades the Batch 1 lead.\n\nBatch 11 (7 Oct 2026) runs channel 1 on California — the statute name joined to *retaliation* and *First Amendment* — and finds the only California case in the record where a court actually reached the question of retaliatory motive for a § 5150 hold, and rejected it on the facts after trial.\n\nBatch 12 (7 Oct 2026) runs channels 2 and 9 on California together: the patients'-rights complaint channel and the shape of what it reports upward.\n\nBatch 13 (7 Oct 2026) begins the US state sweep at Arizona under the method: channel 1 (Title 36 procedure names in case law and session laws). Arizona's initiation rules are the loosest yet \\[corrected, Batch 18/D02: ranking withdrawn; the enacted 2024 law kept screening-agency filing\\] mapped in the United States and were amended (applicant notice and reasons; not loosened — corrected Batch 18/D02) in 2024.\n\nBatch 14 (7 Oct 2026) runs channels 2, 4 and 6 on Arizona: the statutory oversight committee for the state hospital, the P&A litigation over access, and the historical federal investigation. The oversight channel yields a documented, recurring retaliation-for-grievance pattern at the Arizona State Hospital — the first US institutional instance of Mechanism 9 in the record.\n\nBatch 15 (7 Oct 2026) opens Texas under channel 1 (Chapter 573 instrument names and session laws) and channel 2 (a municipal police-oversight complaint file). Texas shows a different design from Arizona: initiation is officer- and facility-led, and the legislature has explicitly carved the facility hold \\[corrected, Batch 18/D01: SB 359 was vetoed 2 Jun 2015; this describes a proposal, not law\\] out of the firearm-record consequence.\n\nBatch 16 (7 Oct 2026) tests two of the revised-method corrections. The reverse sequence (start from known complainants) run on US protest activists returned no psychiatric instrument at all — a pattern finding in itself — and one Russian case missing from the register. The \"litigious as symptom\" archival question, run on US courts, returned a live mechanism the record had not yet named: civil-court competency inquiries under Rule 17(c) and vexatious-litigant orders, including one initiated by the opposing party.\n\nBatch 17 (7 Oct 2026) is a cross-cut rather than a jurisdiction: channel 7 (timing) read back across every row in the record, plus one new witness case. It produces the first *interval* table — the distance in days between the speech act and the psychiatric act — and a pattern about how the law itself converts a hospitalization into impeachment.\n\nBatch 18 (7 Oct 2026) is a correction batch. The parallel thread's edition 02 audited Batches 1–15 and found seven errors or overstatements (its items D01–D07) plus three carried from edition 01. Each is checked here against the primary text where possible, and the affected rows are amended rather than deleted so the error stays visible. Channel 10 (key cross-check) is then run on edition 01's twelve supplement cases and edition 02's longitudinal notes.\n\n\n\n**Verification labels used throughout**\n\n| Label | Meaning |\n| --- | --- |\n| VERIFIED | Claim traced to a primary source (statute, judgment, official report) or to a source opened during this batch and linked in the bibliography |\n| SUPPORTED | Claim rests on a credible secondary account (scholarly history, major investigative reporting) not yet traced to the primary record |\n| LEAD | Plausible and widely repeated, but not yet checked against a primary or credible source in this thread — do not cite onward until verified |\n| DISPUTED | Primary sources conflict, or later evidence undercuts the standard account |\n\n**Outcome labels** (never collapsed into one another): ALLEGATION · JUDICIAL FINDING · OFFICIAL FINDING (audit, inspector, legislative committee) · SETTLEMENT (no liability established) · ADMISSION · REJECTED (allegation examined and not sustained).\n\n**Mechanism labels** (legal instrument actually used): 5150 (California 72-hour hold, Welf. & Inst. Code § 5150 only) · 5250 (14-day certification) · LPS-CONSERVATORSHIP · PROBATE-CONSERVATORSHIP · COMPETENCY-EXAM · FITNESS-FOR-DUTY · VOLUNTARY-ASSESSMENT · NON-CA-HOLD (another jurisdiction's emergency hold, named) · LONG-COMMITMENT · THREAT-ONLY (no detention occurred).\n\n**Effect labels**: PURPOSE-EVIDENCE (documents, testimony, or findings showing the intervention was aimed at silencing) · EFFECT-EVIDENCE (harm or deterrence shown, intent not established) · CHILL-TESTIMONY · CHILL-RESEARCH · CHILL-OFFICIAL · CHILL-INTERPRETATION (my inference, flagged as such).\n\n**Dedup keys for the parallel thread**: each register row carries a key of the form `YEAR-JURISDICTION-SHORTNAME` (e.g., `1971-CA-ELLSBERG-FIELDING`). Match on the key before merging.\n\n## Geographic coverage index\n\nStatus as of Batch 2. \"Researched\" means at least one register row rests on a source opened in this thread; \"Lead\" means a named case or system is known but unverified here; \"Not yet searched\" means no query has been run. The parallel thread should mark its own coverage against this table before dividing work.\n\n| Region | Researched (rows exist) | Outstanding leads (named, unverified) | Not yet searched |\n| --- | --- | --- | --- |\n| US — federal | Supreme Court commitment doctrine; federal fitness-for-duty exams (1978 finding, MSPB surveys); military discharges (HRW/DoD IG); Ellsberg records burglary | Goldwater rule origin (1964 *Fact* survey, APA 1973); CIA MKUltra psychiatric experimentation; Alaska Mental Health Enabling Act 1956 \"Siberia bill\" panic; VA whistleblower exams; Sell v. United States | Federal Bureau of Prisons psychiatric transfers (Vitek follow-on); immigration detention psychiatric holds |\n| US — states researched | California (chapter); New York (Schoolcraft; Bly 1887); Virginia (Raub); Florida (Donaldson; Baker Act child exams 36,000–38,000+/yr); Illinois (Packard; Lincoln 1875 lead); Michigan (Ionia/Metzl); Massachusetts (Shea 2022 disparities); Texas (Addington); Wisconsin (Lessard) | — | — |\n| US — state leads | — | Alaska (1956); Alabama (Wyatt v. Stickney 1972); Georgia (Milledgeville; Parham 1979); Indiana (Jackson 1972); Kansas (Hendricks 1997); Louisiana (Cartwright 1851); Missouri (Sell 2003); Nebraska (Vitek 1980); New Jersey (Rennie v. Klein); Oregon (Insane Liberation Front 1970; civil commitment data); Pennsylvania (Byberry); Washington (Harper 1990; Farmer DISPUTED); D.C. (Ervin Act 1964; St. Elizabeths/Pound) | Arizona, Arkansas, Colorado, Connecticut, Delaware, Hawaii, Idaho, Iowa, Kentucky, Maine, Maryland, Minnesota, Mississippi, Montana, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, Wyoming |\n| US — D.C. and territories | — | D.C. (above) | Puerto Rico, Guam, U.S. Virgin Islands, American Samoa, Northern Mariana Islands |\n| Europe — west | United Kingdom (MHA ethnic detention rates 2023–25; Wessely review; Mental Health Bill 2025); Netherlands (Winterwerp, cited) | France (Camille Claudel 1913–43; Hersilie Rouy); Italy (Basaglia Law 180, 1978); Spain (Vallejo-Nágera's 1938–39 studies on Republican prisoners); Germany (T4 1939–41 as the limit case); Ireland (Magdalene/asylum overlap) | Portugal, Belgium, Austria, Switzerland, Nordic countries, Greece |\n| Europe — east and former USSR | USSR (systemic, admitted 1989); Russia (2019–2023 resurgence: Gabyshev, Petrova, Onoshkin, Nepein, Kuzmina — 7+ cases) | East Germany (Süß 1998: no Soviet-style system, individual Stasi cases — DISPUTED); Romania (Ceaușescu era, Amnesty 1980s); Uzbekistan (Urlaeva); Turkmenistan (Durdykuliev 2004); Belarus (post-2020); Ukraine (Soviet era; post-2014) | Poland, Czechoslovakia, Hungary, Bulgaria, Yugoslavia (WPA found 1980s reports inconclusive), Baltic states, Georgia, Armenia, Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, Moldova |\n| East Asia | China (Ankang; 2013 law; petitioners 2015–21) | Japan (shitaku kanchi 1900–1950; Utsunomiya 1984; long-stay \"social hospitalization\"); South Korea (Constitutional Court 2016 on guardian-initiated commitment); Taiwan (martial-law era) | North Korea, Mongolia, Hong Kong, Macau |\n| South and Southeast Asia | — | India (Erwadi 2001; Mental Healthcare Act 2017; colonial lunatic asylums); Pakistan; Sri Lanka | Bangladesh, Nepal, Indonesia (pasung shackling), Philippines, Vietnam, Thailand, Myanmar, Cambodia, Malaysia, Singapore |\n| Middle East and North Africa | — | Iran (activists sent for evaluation, 2010s–2020s); Turkey; Egypt (Abbasiya); Israel/Palestine | Saudi Arabia, Gulf states, Iraq, Syria, Lebanon, Jordan, Morocco, Algeria, Tunisia, Libya |\n| Sub-Saharan Africa | — | South Africa (apartheid-era private institutions; WHO 1977 report; 2016 Life Esidimeni deaths); Nigeria (chaining and \"prayer camps\" — HRW 2019); Ghana; Kenya | All other states |\n| Oceania | New Zealand (Lake Alice: Royal Commission *Beautiful Children* 2022; UN CAT 2020 and 2022; government acknowledgment of torture 2024) | Australia (Chelmsford deep-sleep therapy, Slattery Royal Commission 1990; Indigenous detention disparities; Victoria/NSW Royal Commissions) | Pacific island states, Papua New Guinea |\n| Americas — north | Canada/Quebec (Duplessis Orphans: false diagnoses 1935–64; apology 1999/2001; compensation 2001/2006/2007) | Canada: MKUltra at Allan Memorial (Cameron); Indigenous and residential-school psychiatric records; Ontario Huronia | Mexico |\n| Americas — Latin America and Caribbean | Brazil (Colônia de Barbacena: \\~60,000 deaths; \\~70% admitted without diagnosis; closed 25 May 2026) | Cuba (Brown & Lago 1991); Argentina and Chile (dictatorship-era psychiatry); Uruguay; Peru | Colombia, Venezuela, Bolivia, Paraguay, Ecuador, Central America, Caribbean states |\n| Supranational | WPA (1977–1989); ECHR (Winterwerp; HL v. UK); UN CRPD; UN CAT (New Zealand findings) | Inter-American Commission (Ximenes Lopes v. Brazil 2006); African Commission | — |\n\n**Batch 3 status changes.** Moved to *Researched*: Michigan (Denhof), Maryland (Blake), Oregon (Springfield), Missouri (Ashland), Minnesota (Duluth, filed 2026), Illinois (7th Cir. mayoral-election exam case — jurisdiction to confirm); South Korea; Japan; Spain; East Germany; Iran; Kazakhstan and Crimea (via the 2017 FIDH/Civic Solidarity report). US national framework added (Hedman 2016; LawAtlas). Still *Lead*: Alaska 1956 and the Goldwater rule (both upgraded to SUPPORTED on standard sources, not yet opened); Romania; Cuba; Argentina/Chile; Australia; South Africa; Turkey; India. The *Not yet searched* column is unchanged except Illinois, Maryland, Minnesota, Missouri and Oregon.\n\n**Batch 4 status changes.** Moved to *Researched*: Romania; Cuba; Australia (NSW); South Africa. Still *Lead*: Argentina, Chile, Turkey, India, Nordic and Benelux, remaining US states and territories.\n\n**Batch 5 status changes.** Moved to *Researched*: Argentina; Chile; Uruguay (via the Polis comparative article). Still *Lead*: Turkey, India, Nordic and Benelux, remaining US states and territories; Mexico, Peru and the rest of Latin America remain *Not yet searched*.\n\n**Batch 6 status changes.** Moved to *Researched*: Turkey; India; the Nordic group (Denmark, Finland, Norway, Sweden, Iceland) and the 22-country European/Oceania comparison (Austria, Italy and England figures recorded). Still *Lead*: Benelux individually, Mexico, Peru, and the US state sweep from Arizona.\n\n**Batch 8 status changes.** Moved to *Researched*: Puerto Rico; Belarus; Kazakhstan (Mukhortova, with HRW, ICJ and Lawyers for Lawyers sources). Still *Not yet searched*: Guam, U.S. Virgin Islands, American Samoa, Northern Mariana Islands; Benelux individually; Mexico; Peru; the US state sweep from Arizona.\n\n**Batch 9 status changes.** Moved to *Researched*: France (1838 law; Claudel). Still *Lead*: Italy (Basaglia Law 180). The remaining *Not yet searched* list is unchanged: Guam, U.S. Virgin Islands, American Samoa, Northern Mariana Islands; 29 US states from Arizona; Benelux individually; Mexico; Peru; the rest of Latin America, Africa, the Middle East, South and Southeast Asia, and the Pacific as listed in the index table.\n\n## Historical overview\n\nThe documented record shows psychiatric authority used to silence people in three recurring forms: detention that removes a person at the moment they speak, diagnosis that discounts what they say afterward, and the standing threat of either, which deters speech before it happens. The strongest purpose-evidence comes from outside California (Soviet forensic files, a federal conviction over the Ellsberg psychiatric-records burglary, a 1978 House subcommittee finding on fitness-for-duty exams). California's own record is dominated by effect-evidence and contested allegations, not findings of retaliatory intent.\n\n**Before the LPS Act.** Nineteenth-century American commitment ran on private initiative with thin judicial checks: Illinois law let a husband commit his wife on his own request (Elizabeth Packard, 1860), and Nellie Bly's 1887 Blackwell's Island exposé showed how little evidence an admission required. California's pre-1967 scheme allowed indeterminate commitment with lasting legal disabilities for anyone adjudicated mentally ill (see Thorn v. Superior Court, 1970, describing the repealed law). The medical categories of the era were elastic enough to pathologize status and dissent — Cartwright's 1851 \"drapetomania,\" and a century later the \"protest psychosis\" literature Jonathan Metzl traced through Ionia State Hospital's records.\n\n**The LPS turn.** A two-year Assembly subcommittee study produced the November 1966 report *The Dilemma of Mental Commitments in California*, which framed the problem as a forced choice between \"the medical objectives of treating sick people without legal delays\" and due process ([Thorn](https://scocal.stanford.edu/opinion/thorn-v-superior-court-27536), quoting the report). The Lanterman-Petris-Short Act (Stats. 1967, ch. 1667) became operative 1 July 1969, ended indeterminate commitment, removed the legal disabilities of adjudication, and replaced them with time-limited holds: 72 hours under § 5150, 14-day certification under § 5250, and conservatorship. The 1969 amendments added the right to counsel on certification. Petris later said the community funding promised with the Act never materialized ([Local News Matters, 2020](https://localnewsmatters.org/2020/07/30/state-audit-urges-improved-treatment-for-people-with-mental-illnesses/)).\n\n**What § 5150 is and is not.** Section 5150 authorizes a peace officer or county-designated professional, on probable cause, to take a person into custody for up to 72 hours of evaluation when, as a result of a mental disorder, the person is a danger to others, to self, or gravely disabled. It is not a commitment, a competency examination, a conservatorship, or a voluntary assessment. Its design features — low threshold, no pre-detention hearing, statutory immunity for those acting under it (§ 5278), and a firearm prohibition that attaches to qualifying admissions \\[corrected, Batch 18/E01: § 8103(f) requires custody, assessment and admission as a danger to self or others — not every hold\\] (§ 8103) — are exactly the features that make it both a workable emergency tool and a credible threat. Volume is large: DHCS reported roughly 131,000–136,000 adult 72-hour admissions a year in fiscal 2016–17 and 2017–18 ([DHCS FY17-18 report](https://www.dhcs.ca.gov/Documents/CSD_YV/MHSA/IDR/FY17-18-IDR-Report.pdf); column reading flagged for re-check).\n\n**The California evidence problem.** The State Auditor's 2020 review of 60 holds and 60 conservatorships in three counties found the criteria appropriately applied in every case sampled and \"no evidence to justify any changes to the criteria\" ([Report 2019-119](https://information.auditor.ca.gov/reports/2019-119/index.html)). But the audit was not designed to detect retaliatory use, its hold data from the Department of Justice cover only danger-based holds, and in 2023 only 32 of 58 counties submitted the newer LPS data set ([DHCS 2025 LPS Annual Report](https://www.dhcs.ca.gov/ru/formsandpubs/forms/Documents/2025-LANTERMAN-PETRIS-SHORT-ACT-ANNUAL-REPORT.pdf)). When individuals do sue, § 5278 immunity, the absence of a private right of action under the Act, and the rule that private hospitals are not state actors usually end the case before any finding on motive (Julian v. Mission Community Hospital, 2017). The result is a record rich in allegations and thin in adjudicated findings — which is itself a finding about how the system allocates the burden of proof.\n\n**The international frame.** Soviet psychiatry supplied the paradigm case: a diagnosis (\"sluggish schizophrenia\") built to absorb dissent, a forensic institute (Serbsky) to apply it, and a 1989 acknowledgment by the Soviet delegation to the World Psychiatric Association that systematic political abuse had occurred ([HRW, 2002](https://www.hrw.org/reports/2002/china02/china0802-02.htm)). China's police-run Ankang hospitals and the continued confinement of petitioners after the 2013 Mental Health Law show the pattern persisting under a reformed statute. These systems differ from California in the decisive respect that the state itself designed the mechanism for political use; the comparison is useful for identifying mechanisms, not for inferring motive in any California case.\n\n## Annotated historical timeline (Batch 1 spine)\n\nOldest first. Entries marked VERIFIED were traced to a primary source or a page opened in this batch; SUPPORTED rests on a standard secondary account not yet opened here; LEAD needs checking before onward use.\n\n| Date | Jurisdiction | Event | Mechanism | Outcome / finding | Label | Source |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1851 | Louisiana (US) | Samuel Cartwright publishes \"drapetomania,\" a purported disease causing enslaved people to flee | Diagnostic category | Discredited; standard example of race-based pathologizing | SUPPORTED | Cartwright, New Orleans Medical and Surgical Journal (1851) |\n| 1860–1864 | Illinois (US) | Elizabeth Packard committed by her husband under an 1851 law allowing commitment of married women on the husband's request; released 1863; 1864 jury finds her sane | Family-initiated commitment, no hearing | Jury verdict of sanity; Illinois \"Personal Liberty Law\" 1867 | SUPPORTED | Packard, *The Prisoners' Hidden Life* (1868); Himelhoch & Shaffer, *Journal of American History* (1979) |\n| 1887 | New York (US) | Nellie Bly feigns insanity, is committed to Blackwell's Island, reports conditions | Admission on minimal evidence | Grand jury inquiry; budget increase | SUPPORTED | Bly, *Ten Days in a Mad-House* (1887) |\n| 1945–1958 | US federal | Ezra Pound found unfit for trial on treason; held at St. Elizabeths; indictment dismissed 1958 | COMPETENCY-EXAM | Whether the finding was genuine or a device to avoid trial is contested | DISPUTED | Torrey, *The Roots of Treason* (1984) |\n| 1957–1971 | Florida (US) | Kenneth Donaldson committed on his father's petition, held \\~15 years without treatment; Supreme Court 1975 | LONG-COMMITMENT | JUDICIAL FINDING: state cannot confine a non-dangerous person able to live safely in freedom | VERIFIED | [O'Connor v. Donaldson, 422 U.S. 563 (1975)](https://supreme.justia.com/cases/federal/us/422/563/) |\n| 1960s–1970s | Michigan (US) | Ionia State Hospital records show schizophrenia diagnosed with rising frequency in Black men, with civil-rights language in charts | Diagnostic category | Archival finding (Metzl); Bromberg & Simon coin \"protest psychosis\" 1968 | SUPPORTED | Metzl, *The Protest Psychosis* (2009) |\n| Nov 1966 | California | Assembly Subcommittee on Mental Health Services publishes *The Dilemma of Mental Commitments in California* | Legislative study | Frames LPS debate | VERIFIED | Cited in Thorn (1970); [Capitol Weekly](https://capitolweekly.net/the-forgotten-report-that-upended-mental-health-care/) |\n| 1967 / 1 Jul 1969 | California | LPS Act enacted (Stats. 1967, ch. 1667); operative 1 July 1969; 1969 amendment adds right to counsel on certification | Statute | Ends indeterminate commitment; creates §§ 5150, 5250 | VERIFIED | [Thorn v. Superior Court (1970) 1 Cal.3d 666](https://scocal.stanford.edu/opinion/thorn-v-superior-court-27536) |\n| Jul–Aug 1969 | San Diego, California | Hospital refuses court-appointed counsel access to a certified patient (\"Mrs. Green\"); she is discharged near the end of the 14-day period once a habeas writ issues | 5250 | Supreme Court upholds the court's order that appointed counsel visit all certified patients | VERIFIED | Thorn, fn. 6 |\n| 26 Jan 1970 | California | Thorn v. Superior Court: certification is \"tantamount to a request for release\"; court notes \"role conflict\" when the treating facility explains the patient's rights | Judicial construction of LPS | JUDICIAL FINDING on safeguards | VERIFIED | Thorn (1970) |\n| 1971 | USSR | Bukovsky smuggles forensic reports on six confined dissidents to the West; sentenced to 12 years | LONG-COMMITMENT (Serbsky forensic diagnosis) | Starts international response | VERIFIED (secondary) | [HRW 2002](https://www.hrw.org/reports/2002/china02/china0802-02.htm); [Psychiatric News 2010](https://psychiatryonline.org/doi/10.1176/pn.45.22.psychnews_45_22_024) |\n| 3 Sep 1971 | Beverly Hills, California | White House \"Plumbers\" burgle psychiatrist Lewis Fielding's office seeking Ellsberg's file to discredit him | Psychiatric records as discrediting tool (no detention) | ADMISSION (Krogh plea) and JUDICIAL FINDING (Ehrlichman conviction 1974, affirmed 1976); Ellsberg prosecution dismissed 1973 | VERIFIED | [Michigan Daily, 18 May 1976](https://digital.bentley.umich.edu/midaily/mdp.39015071754647/118/download_text); [White House Plumbers](https://en.wikipedia.org/wiki/White_House_Plumbers) |\n| Jun 1972 | Newport Beach, California | Martha Mitchell, after phoning a reporter about Watergate, is physically restrained in a hotel and injected with a tranquilizer; her account is publicly treated as delusional, later vindicated | Private restraint and sedation (not 5150) | Later termed the \"Martha Mitchell effect\" (Maher 1988) | SUPPORTED | Standard Watergate histories; LEAD: locate contemporaneous UPI/press record |\n| 1972 | Wisconsin (US) | Lessard v. Schmidt sets due-process minimums for civil commitment | Federal constitutional ruling | JUDICIAL FINDING | SUPPORTED | 349 F. Supp. 1078 (E.D. Wis. 1972) |\n| 1973 | California (Stanford) | Rosenhan, \"On Being Sane in Insane Places,\" Science | Pseudopatient admissions | Later investigation (Cahalan 2019) finds Rosenhan's own records contradict the published account; data for most pseudopatients unverifiable | DISPUTED | Rosenhan, Science 179:250 (1973); Cahalan, *The Great Pretender* (2019) |\n| 1977 | WPA (Honolulu) | Declaration of Hawaii and resolution condemning political misuse of psychiatry, citing the USSR | Professional self-regulation | Soviet society resigns Jan 1983 ahead of expulsion vote; acknowledges systematic abuse at Athens 1989 | VERIFIED (secondary) | [RCPsych Bulletin 1990](https://pb.rcpsych.org/content/14/3/129.full-text.pdf+html); [van Voren 2010](https://pmc.ncbi.nlm.nih.gov/articles/PMC2800147) |\n| 28 Feb 1978 | US federal | Donald Soeken testifies on forced psychiatric fitness-for-duty exams; House subcommittee finds exams \"used as the result of personality conflicts, and for retaliation\" | FITNESS-FOR-DUTY | OFFICIAL FINDING; OPM rules narrowed (now 5 C.F.R. § 339.301) | VERIFIED (secondary) | [Federal Times/MSPB 2014](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/); [Whistleblower Network News](https://whistleblowersblog.org/whistleblower-of-the-week/donald-ray-soeken/) |\n| 1979 | California | Conservatorship of Roulet: proof beyond reasonable doubt and unanimous jury for LPS conservatorship | LPS-CONSERVATORSHIP | JUDICIAL FINDING | SUPPORTED | 23 Cal.3d 219 |\n| 1979 | US Supreme Court | Addington v. Texas: clear-and-convincing standard for civil commitment | Constitutional standard | JUDICIAL FINDING | VERIFIED | [441 U.S. 418](https://supreme.justia.com/cases/federal/us/441/418/) |\n| 1981 | California (9th Cir.) | Doe v. Gallinot: probable-cause hearing required after emergency detention, no later than day seven \\[corrected, Batch 18/E02\\] | 5250 | JUDICIAL FINDING; leads to certification review hearings (§ 5256) | SUPPORTED | 657 F.2d 1017 |\n| 1987 | California | Riese v. St. Mary's Hospital: involuntary LPS patients retain the right to refuse antipsychotic medication absent emergency or a judicial incapacity finding | Right to refuse treatment | JUDICIAL FINDING; codified § 5332 (1991) | SUPPORTED | 209 Cal.App.3d 1303 |\n| 1992–2010 | US federal | MSPB surveys: share of retaliated-against employees reporting fitness-for-duty exams rises from 1.6% to 6.1% | FITNESS-FOR-DUTY | CHILL-RESEARCH (survey) | VERIFIED (secondary) | Federal Times/MSPB 2014 |\n| 2001 | California | AB 1424 requires consideration of the historical course of a person's disorder in LPS decisions | Statute | Widens evidentiary basis for holds | SUPPORTED | [DRC history](https://www.disabilityrightsca.org/system/files/file-attachments/HistoryoftheLPSActAccessibleJuly14202.pdf) |\n| 2002 | China / HRW | *Dangerous Minds* documents political use of Ankang police-psychiatric hospitals | Police-run confinement | Investigative/NGO finding | VERIFIED | [HRW 2002](https://www.hrw.org/reports/2002/china02/china0802-02.htm) |\n| 3 & 31 Jan 2008 | Los Angeles, California | Britney Spears placed on two 5150 holds at UCLA Medical Center; temporary probate conservatorship 1 Feb 2008 | 5150, then PROBATE-CONSERVATORSHIP | 2021 testimony alleges coerced medication and reproductive control; conservatorship ended 12 Nov 2021; allegations disputed, no judicial finding | ALLEGATION | [Billboard timeline](https://www.billboard.com/pro/britney-spears-conservatorship-timeline/); [KQED](https://www.kqed.org/forum/2010101884144/britney-spears-offers-disturbing-testimony-about-conservatorship-that-she-seeks-to-be-free-from) |\n| 31 Oct 2009 | New York (US) | NYPD officer Adrian Schoolcraft, after reporting crime-stat manipulation, is taken from his home and held six days at Jamaica Hospital; a hospital note records no significant symptoms | NON-CA-HOLD (NY Mental Hygiene Law) | SETTLEMENT 2015 (reports range $600k–$1.1M); Queens DA found no crime; NYPD later confirmed the underlying stat manipulation | SETTLEMENT | [NYPD Confidential 2010](https://nypdconfidential.com/columns/2010/100920.html); [NY Daily News 2015](https://www.pressreader.com/usa/new-york-daily-news/20151204/281676843839339) |\n| 16–23 Aug 2012 | Virginia (US) | Marine veteran Brandon Raub detained under a temporary detention order over Facebook posts; special justice orders 30 days; circuit judge dismisses petition as \"devoid of any factual allegations\" | NON-CA-HOLD (Va. TDO) | JUDICIAL FINDING on procedural deficiency, not on motive; later civil suit REJECTED: 4th Cir. affirmed for Campbell 29 Apr 2015 (no First Amendment causation; qualified immunity), cert. denied 16 Nov 2015 \\[corrected, Batch 18/E03\\] | VERIFIED (secondary) | [Rutherford Institute](https://www.rutherford.org/publications_resources/on_the_front_lines/victory_circuit_court_orders_brandon_raub_released_dismisses_case_against_m); [ABC News](https://abcnews.go.com/blogs/politics/2012/08/former-marine-detained-after-alleged-facebook-threats/) |\n| 1 May 2013 | China | First Mental Health Law takes effect; Ankang hospitals largely exempted; petitioners still confined afterward | Statute | NGO documentation of continued use | VERIFIED | [HRW 2013](https://www.hrw.org/news/2013/05/03/china-end-arbitrary-detention-mental-health-institutions); [Dui Hua 2012](https://duihua.org/?p=18355) |\n| May 2016 | US military | HRW *Booted*: sexual-assault survivors discharged with personality/adjustment-disorder labels; DoD IG finds 67% of such discharges lacked required documentation | Diagnostic label as discharge basis | OFFICIAL FINDING (IG) plus NGO investigation; military contested HRW's framing | VERIFIED | [HRW 2016](https://hrw.org/news/2016/05/19/us-raped-military-then-punished); [Task & Purpose](https://taskandpurpose.com/news/soldier-stood-sexual-harassment-kicked-army/) |\n| 2 May 2017 | California | Julian v. Mission Community Hospital: teacher's claims over a 5150 detention fail on immunity, no private right of action, and no state action | 5150 | REJECTED on legal grounds; motive never reached | VERIFIED (secondary) | [Justia summary](https://civilrightsopinions.justia.com/2017/05/02/julian-v-mission-community-hospital) |\n| 28 Jul 2020 | California | State Auditor Report 2019-119 | Audit | OFFICIAL FINDING: criteria applied appropriately in all 120 sampled cases; ongoing-care failures; data gaps | VERIFIED | [Auditor](https://information.auditor.ca.gov/reports/2019-119/index.html) |\n| 2020 | Alameda County, California | Disability Rights California sues county and John George Psychiatric Hospital over repeated short-term holds falling mostly on Black residents; Alameda's hold rate reported at over three times the state average | 5150 pattern | ALLEGATION; outcome LEAD | LEAD | [Daily Beast](https://www.thedailybeast.com/when-going-to-the-hospital-is-just-as-bad-as-jail/) |\n| 2022 | Safeguard Defenders | *Drugged and Detained*: 140+ sources on psychiatric confinement of petitioners and activists in China, 2015–2021 | Police and hospital collusion | NGO finding | VERIFIED | [Safeguard Defenders](https://safeguarddefenders.com/sites/default/files/pdf/EXECUTIVE%20SUMMARY%20EN.pdf) |\n| 2023 | California | DHCS 2025 LPS Annual Report: only 32 of 58 counties submitted calendar-2023 data under SB 929 | Data reporting | OFFICIAL FINDING on data limits | VERIFIED | [DHCS 2025](https://www.dhcs.ca.gov/ru/formsandpubs/forms/Documents/2025-LANTERMAN-PETRIS-SHORT-ACT-ANNUAL-REPORT.pdf) |\n\n## California case and incident register\n\nEach row carries a dedup key. \"Finding\" records only what a court, auditor, or official body actually determined; everything else stays in \"Allegation.\" Note: in this batch no California court or agency has found that a § 5150 hold was imposed to retaliate or silence — the two civil cases that alleged it were resolved on immunity and state-action doctrine before motive was examined.\n\n| Key | Date | People / institutions | Mechanism | Allegation | Finding or outcome | Open questions |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1966-CA-DILEMMA-REPORT | Nov 1966 | Assembly Subcommittee on Mental Health Services (Lanterman chair; Petris; staff authors) | Legislative study | Pre-LPS commitment relied on indeterminate confinement and stripped legal rights | OFFICIAL FINDING; basis of AB 1220 / SB 677 (1967) | Full report text is in few libraries; obtain and quote the sections on abuse of process |\n| 1967-CA-LPS-ENACTED | 1967–1969 | Legislature; Gov. Reagan | Statute (Stats. 1967, ch. 1667; 1968 chs. 1170, 1199, 1374; 1969 ch. 722) | — | Ends indeterminate commitment; creates 72-hour / 14-day / conservatorship ladder; 1969 adds counsel on certification | Wikipedia dates \"full effect\" to 1972 — reconcile with Thorn's \"operative July 1, 1969\" (likely phased county implementation) |\n| 1969-CA-SD-GREEN | 19 Jul–4 Aug 1969 | San Diego private psychiatric hospital (Thorn petitioners); Defenders, Inc.; Superior Court | 5250 | Hospital refused appointed counsel access to a certified patient who, it said, had not asked for a lawyer | Patient discharged near the end of certification once a writ issued; Supreme Court upheld the court's standing order (Thorn, 1970) | Not retaliation — but a documented early instance of a facility controlling a detained person's access to counsel |\n| 1970-CA-THORN | 26 Jan 1970 | Cal. Supreme Court; Citizens Advisory Council amicus | Judicial construction | — | JUDICIAL FINDING: refusal of voluntary treatment is \"tantamount to a request for release\"; court flags \"role conflict\" in having the treating facility explain rights | Did counties adopt the suggested third-party rights advisement? Trace to §§ 5252.1, 5256 history |\n| 1971-CA-ELLSBERG-FIELDING | 3 Sep 1971 | White House Plumbers (Krogh, Liddy, Hunt, Cuban operatives); Dr. Lewis Fielding, Beverly Hills; Daniel Ellsberg | Psychiatric records sought to discredit a whistleblower (no detention, no 5150) | Operation aimed to build a \"psychiatric profile\" to discredit Ellsberg | ADMISSION (Krogh guilty plea); JUDICIAL FINDING (Ehrlichman convicted 1974, affirmed 1976; Liddy convicted); Ellsberg prosecution dismissed May 1973 for government misconduct | Strongest purpose-evidence in the California record, though the instrument was records, not confinement |\n| 1972-CA-MITCHELL | Jun 1972 | Martha Mitchell; security guard Steve King; a physician; Newport Beach hotel | Private physical restraint and forced sedation (not 5150) | Restrained and injected after phoning UPI's Helen Thomas about Watergate; her account publicly dismissed as drunkenness or delusion | Later corroborated by Watergate record; no legal proceeding over the restraint located | LEAD: find contemporaneous UPI/press accounts and King's later statements; confirm no 5150 was invoked |\n| 1973-CA-ROSENHAN | 1973 | David Rosenhan, Stanford; 12 hospitals (locations partly in California) | Pseudopatient admission | Hospitals cannot distinguish sane from insane; labels stick | DISPUTED: Cahalan (2019) found Rosenhan's notes contradict the article and most pseudopatients cannot be verified | Treat as a caution about evidence quality, not as proof of institutional failure |\n| 1977-CA-DOE-GALLINOT | 1977–1981 | \"John Doe\"; LA County mental health director Gallinot; 9th Circuit | 5250 | Fourteen-day certification without any hearing violated due process | JUDICIAL FINDING (657 F.2d 1017): probable-cause hearing required; § 5256 certification review hearings follow | Open the opinion; confirm facts of the underlying detention |\n| 1979-CA-ROULET | 1979 | Cal. Supreme Court | LPS-CONSERVATORSHIP | — | JUDICIAL FINDING (23 Cal.3d 219): reasonable-doubt standard, unanimous jury | Later narrowing by Conservatorship of John L. (2010)? LEAD |\n| 1987-CA-RIESE | 1987 | Eleanor Riese; St. Mary's Hospital, San Francisco; California Alliance for the Mentally Ill (amicus) | Forced antipsychotic medication under LPS | Involuntary patients medicated without consent or capacity determination | JUDICIAL FINDING (209 Cal.App.3d 1303); codified Welf. & Inst. Code § 5332 (1991) | Riese capacity hearings are the main in-hold safeguard — Batch 2: how often are they requested and granted? |\n| 2008-CA-SPEARS | 3 & 31 Jan 2008; Feb 2008–12 Nov 2021 | Britney Spears; UCLA Medical Center; LA Superior Court (Judge Penny); conservators incl. Jamie Spears | 5150 (twice), then PROBATE-CONSERVATORSHIP (not LPS) | 23 Jun 2021 testimony: forced lithium, IUD removal refused, work compelled; characterized by her as retaliation for refusing shows | ALLEGATION; father's counsel disputed and asked the court to investigate; conservatorship terminated 2021 without findings on the allegations | Court investigator reports remain sealed? AB 1194 (2021) reforms traced to this case — verify |\n| 2016–2017-CA-JULIAN | 2017 (events earlier) | Katia Julian, LAUSD middle-school teacher; school police; Mission Community Hospital; examining physician | 5150, overnight admission | No probable cause; detention followed a workplace dispute (officers were investigating an alleged assault on Julian) | REJECTED on legal grounds (11 Cal.App.5th 360): no private right of action under LPS; § 5278 immunity; qualified immunity; hospital not a state actor | The appellate opinion never reaches whether the hold was retaliatory — a structural gap, not an exoneration |\n| 2020-CA-AUDIT-2019-119 | 28 Jul 2020 | California State Auditor; LA, SF, Shasta counties | Audit of 60 holds and 60 conservatorships | — | OFFICIAL FINDING: criteria applied appropriately in all sampled cases; \\~7,400 LA County residents had 5+ holds in FY2015–16 to 2017–18, 9% enrolled in intensive care; DOJ data cover only danger-based holds | Sample was not selected to detect misuse; grave-disability holds unmeasured |\n| 2020-CA-ALAMEDA-DRC | 2020 (filed) | Disability Rights California; Alameda County; John George Psychiatric Hospital | 5150 pattern | Repeated short-term holds without connection to care, falling mostly on Black residents; county hold rate >3x state average | ALLEGATION; hospital counsel called the race allegations \"superfluous\" | LEAD: docket number, current status, any settlement terms |\n| 2023-CA-SB43 | 2023 (effective 2024–2026) | Legislature | Statute | — | Expands \"gravely disabled\" to severe substance use disorder and inability to provide for medical care or personal safety | SUPPORTED, text not opened in this batch; monitor for effect on hold volumes |\n\n## International comparison register\n\nThese cases establish that psychiatry can be organized as an instrument of political control; they do not establish anything about any California case. The last column states the structural difference from California in each instance.\n\n| Key | Country / period | Mechanism | Documentation and status | Similarity to California | Difference from California |\n| --- | --- | --- | --- | --- | --- |\n| 1960s–1980s-USSR-PUNITIVE | USSR, c. 1960–1989 | Forensic diagnosis (Snezhnevsky's \"sluggish schizophrenia,\" with symptoms such as \"reform delusions\"), Serbsky Institute evaluations, special psychiatric hospitals; estimated one-third of political prisoners held psychiatrically | ADMISSION by the Soviet delegation at the 1989 WPA Athens congress; Bukovsky's 1971 documents; Bloch & Reddaway, *Psychiatric Terror* (1977/1984); [van Voren 2010](https://pmc.ncbi.nlm.nih.gov/articles/PMC2800147) | Elastic diagnostic categories; psychiatric labels discounting a speaker's later testimony | State designed the mechanism; no independent courts, counsel, or habeas; confinement indefinite |\n| 1971-USSR-BUKOVSKY | USSR, 1971 | Dissident smuggles six forensic files to the West; sentenced to 12 years | VERIFIED (secondary): [HRW 2002](https://www.hrw.org/reports/2002/china02/china0802-02.htm); [Psychiatric News](https://psychiatryonline.org/doi/10.1176/pn.45.22.psychnews_45_22_024) | Whistleblowing about psychiatric misuse itself punished | Punishment by criminal sentence, not by psychiatry |\n| 1977-WPA-HAWAII | WPA, Honolulu 1977; Vienna 1983; Athens 1989 | Professional-body sanction: Declaration of Hawaii; Soviet society resigns Jan 1983 ahead of expulsion; readmission conditioned on \"sincere co-operation\" | VERIFIED (secondary): [RCPsych Bulletin 1990](https://pb.rcpsych.org/content/14/3/129.full-text.pdf+html) | Model for professional oversight external to the state | California has no equivalent external professional sanction mechanism for individual holds |\n| 1980s–present-CHINA-ANKANG | China, 1980s–present | Police-run Ankang hospitals (about 20 as of 2011); petitioners, Falun Gong practitioners, and activists confined; since 2010s mostly in ordinary wards with police–hospital cooperation | VERIFIED: [HRW 2002 *Dangerous Minds*](https://www.hrw.org/reports/2002/china02/china0802-02.htm); [HRW 2013](https://www.hrw.org/news/2013/05/03/china-end-arbitrary-detention-mental-health-institutions); [Safeguard Defenders 2022](https://safeguarddefenders.com/sites/default/files/pdf/EXECUTIVE%20SUMMARY%20EN.pdf) (140+ sources, 2015–2021) | Confinement used against complainants and petitioners — the closest analogue to \"silencing a person who files grievances\"; NGO notes it \"acts as a deterrent\" | Police run or direct the facilities; the 2013 law exempts Ankang hospitals; no effective court review |\n| 1992–2005-CHINA-WANG-WANXING | China | Wang Wanxing held 13 years after a Tiananmen protest; on release to Germany, two psychiatrists found no disorder justifying admission | VERIFIED (secondary): [RFA 2011](https://www.rfa.org/english/news/china/mental-12282011101351.html) | Single-person long confinement with post-hoc independent evaluation contradicting the diagnosis | Length and absence of review have no California parallel under LPS time limits |\n| 2013-CHINA-MHL | China, 1 May 2013 | First national Mental Health Law; independent review provisions; Ankang largely exempt | VERIFIED: [Dui Hua 2012](https://duihua.org/?p=18355); [CHRD via Amnesty UK 2013](https://www.amnesty.org.uk/knowledge-hub/all-resources/chrb-six-months-after-mental-health-law-took-effect-involuntary-psychiatric/) documents petitioners confined within months of effect | Reform statute that leaves the enforcement channel intact — compare LPS immunity and no-private-right-of-action gaps | Different scale and intent |\n| 1979-ECHR-WINTERWERP | Council of Europe | Winterwerp v. Netherlands sets three conditions for lawful detention of \"persons of unsound mind\": objective medical expertise, a disorder warranting confinement, and persistence of the disorder | SUPPORTED (standard citation: ECtHR 24 Oct 1979, App. 6301/73) | Comparable to Addington / O'Connor minimums | Supranational court review of national practice; no US equivalent |\n| 2004-ECHR-HL-UK | United Kingdom | HL v. UK (Bournewood): informal detention of a compliant incapacitated patient violated Art. 5 | SUPPORTED | Highlights \"voluntary\" admissions that are not voluntary — relevant to California's voluntary/involuntary boundary | — |\n| 2006–2015-UN-CRPD | UN | Convention on the Rights of Persons with Disabilities, Art. 14; 2015 Committee guidelines treat deprivation of liberty on the basis of impairment as discriminatory | SUPPORTED | Frames all disability-based detention, including LPS, as rights-contrary | US has signed but not ratified; no domestic effect |\n| 2007–2014-RUSSIA-RESURGENCE | Russia | Larisa Arap (2007, Murmansk); Mikhail Kosenko (Bolotnaya case, court-ordered treatment 2013, released 2014) | LEAD: verify dates and dispositions against primary reporting | Post-reform recurrence | — |\n| 2001–2017-UZBEKISTAN-URLAEVA | Uzbekistan | Human-rights monitor Elena Urlaeva repeatedly confined in psychiatric clinics | LEAD: verify episode dates | Repeated short confinements timed to activism | — |\n| 1900–1987-JAPAN | Japan | 1900 custody law legalized home confinement (shitaku kanchi); 1984 Utsunomiya Hospital deaths; 1987 Mental Health Act reform | SUPPORTED | Family-initiated confinement as in Packard-era US | — |\n| 2009–2016-US-MILITARY | United States (federal) | Personality/adjustment-disorder discharges after sexual-assault reports; 31,000+ personality-disorder discharges FY2001–2010; DoD IG (2016) finds 67% of such discharges of assault reporters lacked required documentation | VERIFIED: [HRW *Booted*](https://hrw.org/news/2016/05/19/us-raped-military-then-punished); DoD IG DODIG-2016-088 | Diagnosis as a credibility and benefits penalty for complainants | Federal, not state; label without confinement |\n| 1978-US-FITNESS-FOR-DUTY | United States (federal) | Forced psychiatric fitness-for-duty exams of employees in conflict with managers; 1978 House subcommittee finding of retaliatory use; MSPB surveys 1992–2010 | VERIFIED (secondary): [Federal Times/MSPB](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/) | Threat of evaluation as workplace deterrent, with survey evidence of chill | Evaluation rather than detention; regulated by OPM rules |\n| 2009-US-NY-SCHOOLCRAFT | New York | Emergency admission of a police whistleblower; six-day hold; hospital note found no significant symptoms | SETTLEMENT (2015); Queens DA: no crime | Closest US analogue to a 5150 used at the moment of disclosure | NY Mental Hygiene Law § 9.39, not LPS |\n| 2012-US-VA-RAUB | Virginia | Temporary detention order over political Facebook posts; circuit judge dismissed petition as lacking factual allegations | JUDICIAL FINDING (procedural); Raub's civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\] | Speech-triggered hold | Virginia TDO procedure includes a special-justice hearing within days — a step LPS lacks at the 72-hour stage |\n\n## United States national and state register\n\nCalifornia rows stay in the California chapter. Rows here cover federal doctrine and other states; the mechanism column names the actual legal instrument, never \"5150\".\n\n| Key | Jurisdiction / date | People / institutions | Mechanism | Allegation or event | Finding or outcome | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1851-US-LA-CARTWRIGHT | Louisiana, 1851 | Samuel Cartwright; Louisiana Medical Association | Diagnostic category (drapetomania) | Flight from slavery framed as disease | Discredited; cited as the origin case for race-based pathologizing | SUPPORTED |\n| 1860-US-IL-PACKARD | Illinois, 1860–1867 | Elizabeth Packard; Theophilus Packard; Jacksonville State Hospital | Family-initiated commitment under 1851 statute exempting married women from the evidence requirement | Committed for religious dissent from her husband's views | JUDICIAL FINDING (1864 jury: sane); statutory reform 1867 | SUPPORTED |\n| 1887-US-NY-BLY | New York, 1887 | Nellie Bly; Blackwell's Island; New York World | Admission on feigned symptoms | Minimal evidence sufficed for commitment; abuse inside | Grand jury inquiry; appropriations increased | SUPPORTED |\n| 1945-US-DC-POUND | D.C., 1945–1958 | Ezra Pound; St. Elizabeths; Dr. Winfred Overholser | COMPETENCY-EXAM | Found unfit for treason trial | Indictment dismissed 1958; genuineness of the finding contested | DISPUTED |\n| 1956-US-AK-ENABLING-ACT | Alaska, 1956 | Congress; Alaska Mental Health Enabling Act; opponents alleging a \"Siberia\" plan | Legislation | Campaign claimed the Act would allow mass psychiatric detention of political enemies | Act passed; the panic is itself evidence of public fear of psychiatric detention as a political tool | LEAD |\n| 1957-US-FL-DONALDSON | Florida, 1957–1975 | Kenneth Donaldson; Florida State Hospital, Chattahoochee; Dr. O'Connor | LONG-COMMITMENT (father's petition) | Held \\~15 years without treatment though non-dangerous | JUDICIAL FINDING: [O'Connor v. Donaldson (1975)](https://supreme.justia.com/cases/federal/us/422/563/) | VERIFIED |\n| 1964-US-GOLDWATER | US national, 1964–1973 | *Fact* magazine; 1,189 psychiatrists; APA | Diagnostic discrediting without examination | Candidate declared psychologically unfit by polled psychiatrists | Libel verdict for Goldwater (1969); APA \"Goldwater rule\" 1973 | LEAD (verify verdict and rule text) |\n| 1968-US-MI-PROTEST-PSYCHOSIS | Michigan, 1960s–1970s | Ionia State Hospital; Bromberg & Simon (1968) | Diagnostic category | Schizophrenia disproportionately diagnosed in Black men with civil-rights language in charts | Archival finding (Metzl 2009) | SUPPORTED |\n| 1972-US-WI-LESSARD | Wisconsin, 1972 | Alberta Lessard; Milwaukee County | Civil commitment | Commitment without notice, counsel, or hearing | JUDICIAL FINDING: due-process minimums (349 F. Supp. 1078) | SUPPORTED |\n| 1972-US-AL-WYATT | Alabama, 1972 | Bryce Hospital patients | LONG-COMMITMENT | No treatment for the committed | JUDICIAL FINDING: right to treatment (Wyatt v. Stickney) | LEAD |\n| 1978-US-FED-FFD | US federal, 1978–2010 | USPHS; Donald Soeken; House Post Office and Civil Service subcommittee; OPM; MSPB | FITNESS-FOR-DUTY | Exams ordered after personality conflicts and whistleblowing | OFFICIAL FINDING (1978 report quoted in [Federal Times/MSPB](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/)); CHILL-RESEARCH (MSPB 1.6%→6.1%) | VERIFIED (secondary) |\n| 1979-US-TX-ADDINGTON | Texas, 1979 | Frank Addington | Civil commitment | Preponderance standard insufficient | JUDICIAL FINDING: clear and convincing ([441 U.S. 418](https://supreme.justia.com/cases/federal/us/441/418/)) | VERIFIED |\n| 1980-US-NE-VITEK | Nebraska, 1980 | Prisoner Larry Jones | Prison-to-hospital transfer | Transfer without hearing | JUDICIAL FINDING: hearing required (445 U.S. 480) | SUPPORTED |\n| 1990-US-WA-HARPER | Washington, 1990 | Prisoner Walter Harper | Forced medication in prison | Medication without judicial hearing | JUDICIAL FINDING: administrative review suffices (494 U.S. 210) — a limit on safeguards | SUPPORTED |\n| 2009-US-NY-SCHOOLCRAFT | New York, 2009–2015 | Adrian Schoolcraft; NYPD 81st Precinct; Deputy Chief Marino; Jamaica Hospital | NY Mental Hygiene Law emergency admission | Hospitalized hours after reporting crime-stat manipulation; sergeant recorded saying \"I'm going to have him psyched\" | SETTLEMENT (2015); DA: no crime; NYPD confirmed the manipulation | SETTLEMENT |\n| 2012-US-VA-RAUB | Virginia, 2012 | Brandon Raub; Chesterfield police; FBI; John Randolph Medical Center; Salem VA facility | Virginia temporary detention order | Detained over political and lyric posts; held 7 days | JUDICIAL FINDING: petition \"devoid of any factual allegations\"; civil suit REJECTED (4th Cir. 2015; cert. denied) \\[corrected, Batch 18/E03\\] | VERIFIED (secondary) |\n| 2015-US-FL-BAKER-ACT-CHILDREN | Florida, FY2015/16–FY2020/21 | USF Baker Act Reporting Center; school districts; SPLC v. Palm Beach County schools (2021) | Florida Mental Health Act (Baker Act) involuntary examination | 194,354 exams FY15/16; 205,781 FY17/18 incl. 36,078 children; 38,000+ children FY20/21 (+77% in a decade); most child exams initiated at school or by police | OFFICIAL DATA ([DCF/USF report](https://myflfamilies.com/document/21586); [WPTV](https://www.wptv.com/news/local-news/investigations/baker-act-exams-among-florida-children-reach-historic-new-high)); lawsuit ALLEGATION | VERIFIED |\n| 2016-US-MIL-BOOTED | US military, 2001–2016 | HRW; Protect Our Defenders; DoD IG | Personality/adjustment-disorder discharge | Survivors discharged after reporting assault; benefits lost | OFFICIAL FINDING (IG: 67% lacked documentation); military contested framing | VERIFIED |\n| 2022-US-MA-SHEA | Massachusetts, 2012–2018 cohort | 4,393 inpatients | Involuntary admission and court commitment petitions | Black patients aOR 1.57 for involuntary admission | Peer-reviewed finding ([Psychiatric Services 2022](https://psychiatryonline.org/doi/abs/10.1176/appi.ps.202100342)) | VERIFIED (abstract) |\n\n## Worldwide register by region (Batch 2)\n\nNew rows only; Batch 1's USSR, China, WPA, ECHR and CRPD rows stand in the International comparison register above. Local-language sources are named where they were the ones opened.\n\n**Europe**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2023-UK-MHA-ETHNICITY | England, 2022/23–2024/25 | Detention under Mental Health Act 1983; police holding powers; Community Treatment Orders | Black people detained at 228 per 100,000 vs 64 for white people (year to March 2023), 3.5x; 3.8x in 2024/25; CTOs 7x; \\~52,500 detentions in 2023/24; those in the most deprived decile 3.7x more likely | OFFICIAL DATA ([gov.uk Ethnicity facts and figures](https://www.ethnicity-facts-figures.service.gov.uk/health/mental-health/detentions-under-the-mental-health-act/latest/); [Mental Health Bill 2025 fact sheet](https://www.gov.uk/government/publications/mental-health-bill-2025-fact-sheet/mental-health-bill-2025-fact-sheet); [Parliament deposited evidence summary 2025](https://data.parliament.uk/DepositedPapers/Files/DEP2025-0227/Evidence_summary_drivers_of_racial_disparities-Mental_Health_Act.pdf)) | Disparity, not retaliation; NHS says data undercount; drivers contested (access, deprivation, bias) | VERIFIED |\n| 2018-UK-WESSELY | England, 2018–2025 | Independent Review of the MHA; Mental Health Bill 2025 | Detentions rose by over a third 2006–2016; reforms aim to cut detention and disproportionality | OFFICIAL (fact sheet above) | Outcome of the Bill not yet measurable | VERIFIED |\n| 1938-ES-VALLEJO-NAGERA | Spain, 1938–39 and after | Military psychiatric studies of Republican prisoners (Vallejo-Nágera, \"Psiquismo del fanatismo marxista\") | Political opposition theorized as psychobiological inferiority; women prisoners of Málaga studied; linked to removal of children | Scholarly consensus (Vinyes, Bandrés & Llavona); Spanish-language sources to be opened | Not detention by diagnosis; diagnosis legitimizing repression already under way | LEAD |\n| 1913-FR-CLAUDEL | France, 1913–1943 | Family-initiated commitment (loi de 1838) | Camille Claudel confined 30 years at her family's request despite physicians' notes supporting release | Archival record (Montdevergues) | Her diagnosis is itself contested; not a political case | LEAD |\n| 1978-IT-BASAGLIA | Italy, 1978 | Law 180 abolishing asylum admission | Reform model; Trieste | Statute | Implementation uneven by region | LEAD |\n| 1939-DE-T4 | Germany, 1939–41 | State killing of psychiatric patients (\\~70,000) | The limit case of psychiatry as state instrument; not silencing of speakers | Nuremberg Doctors' Trial; German federal acknowledgment | Outside the mission's core question but anchors the spectrum | SUPPORTED |\n| 1998-DDR-SUESS | East Germany, 1949–89 | Stasi use of psychiatry | Süß (1998) found no systematic Soviet-style abuse but individual cases and psychiatrists as informers | Scholarly study on Stasi files | Contrary to the common assumption that every bloc state copied the USSR | DISPUTED / LEAD |\n\n**Russia and former USSR**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2021-RU-GABYSHEV | Russia (Yakutia), 2019–2021 onward | Court-ordered compulsory treatment after forensic finding of \"insanity\" (невменяемость) | Shaman Alexander Gabyshev, who marched toward Moscow to \"exorcise\" Putin, forcibly sent to a dispensary Jan 2021; Yakutsk court ordered compulsory treatment Jul 2021; Yakutia Supreme Court approved transfer 23 Sep 2021; held in Novosibirsk from 25 Sep 2021; still confined as of 2023 | NGO finding: [Amnesty Urgent Action, 7 Oct 2021 (Russian)](https://eurasia.amnesty.org/wp-content/uploads/2021/10/shaman-podvergnut-karatelnoj-psihiatrii.pdf); [Novaya Gazeta Europe, 16 Aug 2023 (Russian)](https://novayagazeta.eu/articles/2023/08/16/osobo-buinye) | Treatment is court-ordered under criminal procedure, so formally lawful; the Independent Psychiatric Association of Russia disputes the diagnosis | VERIFIED (secondary, local-language) |\n| 2023-RU-PETROVA | Russia (St Petersburg), May 2022–Dec 2023 | Pre-trial transfer to psychiatric hospital (Oct 2023); compulsory treatment ordered 25 Dec 2023 for \"army fakes\" (Art. 207.3) | Forensic exam found she \"could not understand her actions\" when posting anti-war videos; lawyer reports she was stripped before male staff, restrained, injected with unknown drugs and could barely speak for days; minimum six months, extendable indefinitely | Court order; survivor account via counsel: [Meduza, 25 Dec 2023 (Russian)](https://meduza.io/news/2023/12/25/sud-v-peterburge-napravil-viktoriyu-petrovu-na-prinuditelnoe-lechenie-v-psihiatricheskiy-statsionar-ee-obvinyali-v-feykah-ob-armii-iz-za-posta-o-shizofrenii-putina); [Moscow Times (Russian)](https://ru.themoscowtimes.com/2023/12/25/obvinyaemuyu-v-voennih-feikah-zhitelnitsu-peterburga-otpravili-na-prinuditelnoe-lechenie-v-psihbolnitsu-a117101) | Prosecution had sought prison; court chose \"mildest\" hospital regime; the hospital account is the defence's | VERIFIED (secondary, local-language) |\n| 2022-RU-ONOSHKIN-NEPEIN-KUZMINA | Russia, 2022–2023 | Compulsory in-patient or out-patient treatment in political cases | Aleksei Onoshkin (Nizhny Novgorod, anti-war posts, Jun 2022 and Oct 2023); Oleg Nepein (Saratov municipal deputy, Sep–Oct 2023); Kuzmina (Moscow, 4 Aug 2023); Moscow Times counts at least seven cases | Local-language reporting (Meduza podcast 28 Nov 2023; Novaya Europe; Moscow Times) | Each is a criminal-procedure forensic outcome; no official admission of political purpose | VERIFIED (secondary) |\n| 2004-TM-DURDYKULIEV | Turkmenistan, 2004 | Psychiatric confinement of a would-be protest organizer | Gurbandurdy Durdykuliev held after requesting permission for a demonstration | HRW/Amnesty reporting | — | LEAD |\n| 2001-UZ-URLAEVA | Uzbekistan, 2001–2017 | Repeated compulsory psychiatric confinement | Human-rights monitor Elena Urlaeva | HRW reporting | — | LEAD |\n\n**Oceania**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1972-NZ-LAKE-ALICE | New Zealand, 1972–1978 | Child and adolescent psychiatric unit; unmodified ECT and paraldehyde used as punishment; seclusion | 362–450 children; many admitted from welfare care without psychiatric diagnosis; shocks for running away or complaining; \\~41% of welfare-residence admissions were Māori; complaints to agencies and professional bodies went uninvestigated for decades | OFFICIAL FINDING: Royal Commission *Beautiful Children* (Dec 2022) finds torture and systemic failure to respond to complaints ([abuseincare.org.nz](https://abuseincare.org.nz/our-progress/news/children-tortured-at-lake-alice-and-failed-by-the-state-royal-commission); [timeline](https://abuseincare.org.nz/reports/inquiry-into-the-lake-alice-child-and-adolescent-unit/executive-summary/timeline)); UN CAT found inadequate investigation (Zentveld, Jan 2020; Richards, Jun 2022); government formally acknowledged torture 2024; one nurse charged Dec 2021, prosecution stayed; Dr Leeks never tried ([Newsroom](https://www.newsroom.co.nz/courts-stay-ends-quest-for-justice); [PMC review](https://pmc.ncbi.nlm.nih.gov/articles/PMC10466991/)) | Mechanism is punishment and silencing of children's complaints, not political dissent; 1977 Ombudsman and Medical Council processes produced no sanction | VERIFIED |\n| 1963-AU-CHELMSFORD | Australia (NSW), 1963–1979 | \"Deep sleep therapy\" at a private hospital; 24+ deaths | Royal Commission (Slattery, 1990) | OFFICIAL FINDING | Malpractice more than silencing; included in the spectrum | LEAD |\n\n**Americas**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1935-CA-QC-DUPLESSIS | Quebec, 1935–1964 | False diagnosis of children as mentally deficient to convert orphanages into subsidized psychiatric hospitals; thousands confined | A 1960s commission found about one-third of patients held under false diagnoses; labels remained on records; Quebec apologies 1999 and 2001; compensation $10,000 + $1,000 per year confined (2001), $26 million (2006), $15,000 each to 1,270 more (2007); Church declined to apologize | OFFICIAL (apology and compensation); Ombudsman Jacoby's 1999 criticism ([Canadian Encyclopedia](https://thecanadianencyclopedia.ca/en/article/duplessis-orphans); [historyofrights.ca](https://historyofrights.ca/encyclopaedia/main-events/duplessis-orphans/); [CBC 1999](https://www.cbc.ca/news/canada/quebec-ombudsman-says-duplessis-orphans-right-1.173120)) | Motive was fiscal, not silencing; but false psychiatric labels discredited survivors' later testimony for decades (the Archbishop demanded case-by-case proof) | VERIFIED |\n| 1903-BR-BARBACENA | Brazil (Minas Gerais), 1903–1980s; closed 25 May 2026 | Hospital Colônia de Barbacena: admissions \"sem critério\" — political militants, \"desafetos\" (personal enemies), unmarried mothers, homosexuals, the poor; \\~70% without a psychiatric diagnosis; \\~60,000 deaths; 1,853 bodies sold to medical schools 1969–80; some admissions signed by police delegates | Investigative record: Arbex, *Holocausto Brasileiro* (2013) and Tribuna de Minas series (2011); Ratton's 1979 film ([Tribuna de Minas, Portuguese](https://tribunademinas.com.br/?p=66135); [Conselho Federal de Psicologia](https://site.cfp.org.br/?p=27644); [closure, May 2026](https://www.portaltela.com/noticias/geral/2026/05/25/hospital-psiquiatrico-que-inspirou-holocausto-brasileiro-e-desativado/)) | Journalistic, not judicial; no prosecutions located (\"50 anos sem punição\"); political admissions are asserted, not quantified | VERIFIED (secondary, local-language) |  |\n| 1991-CU-BROWN-LAGO | Cuba, 1960s–1980s | Psychiatric confinement of dissidents (Mazorra) | Brown & Lago, *The Politics of Psychiatry in Revolutionary Cuba* (1991) | Book-length documentation; AAAS involvement | Single-source dominance | LEAD |\n\n**Asia and Africa (beyond Batch 1's China rows)**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2016-KR-CONSTITUTIONAL | South Korea, 2016 | Guardian-initiated involuntary admission (Mental Health Act art. 24) | Constitutional Court found the provision unconstitutional; 2017 law revision | Judicial finding | Verify date and holding | LEAD |\n| 1984-JP-UTSUNOMIYA | Japan, 1984–1987 | Private hospital deaths; long-stay \"social hospitalization\"; pre-1950 home confinement | Utsunomiya scandal prompted 1987 Mental Health Act | Official/legislative | — | LEAD |\n| 1977-ZA-APARTHEID | South Africa, 1970s | Private Smith Mitchell institutions holding mostly Black patients | WHO 1977 report *Apartheid and Mental Health Care*; APA 1979 visit | Official international reports | Conditions and segregation, not silencing of speakers | LEAD |\n| 2019-NG-SHACKLING | Nigeria and others, 2010s | Chaining in religious and state facilities | HRW 2019 and 2020 global shackling reports | NGO finding | Welfare abuse, not political | LEAD |\n\n**Batch 3 additions**\n\n*United States — national framework and state retaliation findings*\n\n| Key | Jurisdiction / date | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2016-US-50-STATE-HOLDS | All 50 states + D.C., laws as of 2014/2016 | Emergency hold statutes | Every state has one; durations run from 23 hours to 10 days, 72 hours in 22 states; five states do not guarantee assessment by a qualified mental health professional; neither presentation to a judge nor prompt judicial review is uniformly required; 1.27–1.44 million emergency detentions a year nationally, 2013–2015 | Peer-reviewed data set ([Hedman et al., Psychiatric Services 2016](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.201500205); [\"Reasonable or Random\", 2021](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.202000284)); open data at LawAtlas | Describes the instrument, not its misuse; no state records referral context | VERIFIED |\n| 2007-US-MI-DENHOF | Michigan (Grand Rapids), 2001–2007 | Police FITNESS-FOR-DUTY exam | Officer Patricia Denhof, a plaintiff in a sex-discrimination suit, was ordered to an exam after her court testimony; the department psychologist had told the chief that about 75% of officers examined are found unfit; badge and gun confiscated | JUDICIAL FINDING: jury found retaliation; Sixth Circuit affirmed ([Denhof v. City of Grand Rapids, 494 F.3d 534](https://caselaw.findlaw.com/court/us-6th-circuit/1379192.html)) | Civil-rights retaliation, not commitment | VERIFIED (secondary) |\n| 2011-US-MD-BLAKE | Maryland (Baltimore County), 2006–2011 | Police fitness exam and medical-records demand | Officer William Blake ordered to a fitness exam the day after testifying; county dropped the demand only after suit; DOJ investigating the county's practices | JUDICIAL FINDING: $225,000 jury verdict for retaliation, affirmed 4th Cir. ([Daily Record, 2011](https://origintdrdev.wpengine.com/2011/07/17/4th-circuit-affirms-225000-jury-verdict-awarded-to-police-officer)) | — | VERIFIED (secondary) |\n| 2003-US-IL-MAYORAL-EXAM | Illinois (village, 7th Cir.), c. 2003–2004 | Police fitness exam | Officer ordered to an intrusive exam after narrowly losing an election to the incumbent mayor; psychologist advised that refusal should be deemed unfitness for \"undermining the quasi-military hierarchical structure\" | Seventh Circuit reversed dismissal; jury selected on remand ([AELE digest](https://aele.org/psych2004.php)) | Case name and outcome to confirm | LEAD |\n| 2003-US-FED-JURY-325K | US federal district (county employee), 2003 | FITNESS-FOR-DUTY | Jury found the county unlawfully ordered a psychiatric exam and retaliated for a harassment complaint | JUDICIAL FINDING: $325,000 ([AELE digest](https://aele.org/psych2004.php)) | Jurisdiction to confirm | LEAD |\n| 2019-US-OR-SPRINGFIELD | Oregon (Springfield), 2019–2020 | Police fitness exam | Officer Stone ordered to a psychological exam within a month of a finding against him after he challenged colleagues' misconduct | SETTLEMENT $250,000 ([Insurance Journal, 2021](https://amp.insurancejournal.com/news/west/2021/03/02/603368.htm)) | No liability established | SETTLEMENT |\n| 2023-US-MO-ASHLAND | Missouri (Ashland), 2023–2025 | Ordered fitness exam never scheduled; dismissal | Officer Whitener reported the chief breaking the law; told to undergo a psychological exam, then fired without statutory process | SETTLEMENT $1,000,000 ([ABC 17, 2025](https://abc17news.com/?p=1621197)) | Settlement; claim was procedural | SETTLEMENT |\n| 2026-US-MN-DULUTH | Minnesota (Duluth), filed 1 Mar 2026 | Fitness exam after confidential reports | Lt. Drozdowski, head of the behavioral health unit, reassigned, placed on leave and ordered to an exam after reporting officer misconduct; cleared by internal investigation yet still ordered | ALLEGATION (pending) ([Hoodline, 2026](https://hoodline.com/2026/03/duluth-cop-says-city-put-him-on-ice-for-blowing-the-whistle/)) | Filed, untested | ALLEGATION |\n| 1964-US-GOLDWATER | US national, 1964–1973 | Diagnostic discrediting | *Fact* polled psychiatrists; 1,189 declared Goldwater unfit; libel verdict for Goldwater affirmed 1969; APA adopts the \"Goldwater rule\" 1973 | Standard account | Not opened this batch | SUPPORTED |\n| 1956-US-AK-ENABLING-ACT | Alaska / Congress, 1956 | Legislation (P.L. 84-830) | Opponents' \"Siberia bill\" campaign alleged a plan for political detention; the panic shows public fear of psychiatric detention as a tool a decade before LPS | Standard account | Not opened this batch | SUPPORTED |\n\n*East Asia*\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2016-KR-CONSTITUTIONAL | South Korea, 29 Sep 2016 (2014헌가9) | Guardian-initiated commitment (구 정신보건법 §24: two guardians' consent plus one psychiatrist's diagnosis) | Applicant committed Nov 2013 on her two children's consent; the Court noted guardians could collude with a psychiatrist, that this \"often occurred and became a social problem,\" and that private \"emergency transport\" firms kidnapped and assaulted people | JUDICIAL FINDING: unanimous nonconformity ruling; 2016–17 law revision adds dual diagnosis, two-week diagnostic admission and admission-suitability review within one month ([Medigate News, 29 Sep 2016, Korean](https://medigatenews.com/news/2286485391); [PSPD commentary, Korean](https://peoplepower21.org/judiciary/1452956); [Ministry statement 2016, Korean](https://www.incheon.go.kr/welfare/WE010221/1933931)) | Reform law kept a family-initiated route (§43); 69,220 guardian admissions in 2016 per one study | VERIFIED (local-language) |\n| 1883-JP-SOMA-INCIDENT | Japan, 1883–1895 | Family confinement of a feudal lord | Retainer Nishikori Gōsei alleged Lord Sōma Tomotane was wrongfully confined by relatives in an inheritance dispute; the scandal produced the 1900 Mental Patients' Custody Act, which legalized home confinement (私宅監置) for 50 years | Legislative history ([Taiwanese legal abstract](https://lawdata.com.tw/tw/detail.aspx?no=275999); [Utsunomiya, JSSW 2009, Japanese](https://www.jssw.jp/archives/event/conference/2009/57/abstract_57/independent-research/H2_3_1.pdf)) | The founding Japanese case is a family-inheritance dispute — direct parallel to Packard | SUPPORTED (local-language) |\n| 1984-JP-UTSUNOMIYA | Japan (Tochigi), 1984–1987 | Private hospital abuse | Patients beaten to death by staff; UN Sub-Commission and ICJ missions; 1987 Mental Health Act creates designated physicians, voluntary admission, Psychiatric Review Boards | Official legislative chronology ([MHLW 2009, Japanese](https://www.mhlw.go.jp/shingi/2009/07/dl/s0730-11b_0001.pdf); [Cabinet Office paper, Japanese](https://www8.cao.go.jp/shougai/suishin/kaikaku/s_kaigi/k_16/pdf/s2.pdf)) | Reform did not end abuse: MHLW's first survey found 72 suspected abuse cases 2015–19; Takiyama Hospital (Hachioji) 2023 assaults and falsified death certificates ([ben54.jp, Japanese](https://www.ben54.jp/news/2100)) | VERIFIED (local-language) |\n\n*Europe*\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1938-ES-VALLEJO-NAGERA | Spain, Aug 1938–Oct 1939 | Military psychiatric research on prisoners | Franco's telegram of 23 Aug 1938 authorized Vallejo-Nágera's Gabinete de Investigaciones Psicológicas; studies on International Brigade prisoners and 50 Republican women in Málaga prison, published in *Revista Española de Medicina y Cirugía de Guerra* (1938–39), framed Marxism as biopsychic inferiority and women's activism as cruelty; theory invoked for the separation of children of \"red\" mothers (Garzón's 2008 auto estimated \\~30,000) | Scholarly and official-memory sources ([Junta de Andalucía, Lugar de Memoria: Cárcel de Mujeres de Málaga](https://www.juntadeandalucia.es/organismos/culturaydeporte/areas/cultura/memoria-democratica/lugares-memoria-democratica/paginas/antigua-carcel-mujeres.html); [Público](https://www.publico.es/politica/franco-busca-gen-rojo-inferioridad.amp.html); [eHumanista/IVITRA 23](https://ehumanista.ucsb.edu/sites/default/files/sitefiles/ivitra/volume23/1.3.%20Mininni.pdf); [Univ. de Jaén](https://revistaselectronicas.ujaen.es/index.php/rae/article/download/8839/8627/58619)) | Diagnosis legitimized repression already under way; no confinement by diagnosis | VERIFIED (local-language) |\n| 1998-DDR-SUESS | East Germany, 1949–1989 | Stasi and psychiatry | Süß's 773-page study for the Stasi Records Agency found: psychiatrists serving as informers betrayed patient confidences; psychiatric patients were temporarily admitted around state holidays as potential \"disruptors\"; several cases of psychiatric misuse to discipline inconvenient people were proven; but no systematic Soviet- or Romanian-style instrument | Official-archive study ([Bundesarchiv publication page](https://www.bundesarchiv.de/publikationen/publikation/politisch-missbraucht)); Saxony's Psychiatric Abuse Commission final report; a Leipzig researcher's 1972 Waldheim confinement ruled \"not justified\" in a 1992 rehabilitation ([Ärzteblatt](https://www.aerzteblatt.de/archiv/67363/Die-waldheim-story-Psychiatriemissbrauch-selbst-erlebt)) | Critics (Eckstein; FU Berlin journal) argue Süß understated; Süß replied that corrective mechanisms inside GDR psychiatry worked in the cases examined | DISPUTED (both sides opened) |\n\n*Russia, Eurasia and the Middle East*\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2017-FIDH-POST-SOVIET | Russia, Crimea, Kazakhstan, Uzbekistan, Jun 2012–Apr 2017 | Forensic evaluation and compulsory treatment | Named cases: Ilmi Umerov (Crimea); Natalia Ulasik, Zinaida Mukhortova, Alexander Bondarenko, Lyudmila Khromina (Kazakhstan); Mikhail Kosenko, Maxim Panfilov, Stanislav Klykh and nine others (Russia); Jamshid Karimov, Elena Urlaeva (Uzbekistan) | NGO report ([FIDH / Civic Solidarity Platform, April 2017](https://civicsolidarity.org/wp-content/uploads/2017/05/pol-abuse-eng-april-2017-full.pdf)) | Case-by-case; the report itself calls them \"alleged\" | VERIFIED (NGO) |\n| 2022-IR-WLF-PSYCHIATRIC | Iran, 2016–2024 | Transfer of prisoners and protesters to psychiatric hospitals (Aminabad, Razi); judicial \"diagnosis\" as sentence | Kianoush Sanjari chained to a bed two weeks at Aminabad; Hengameh Shahidi sent to Aminabad instead of a medical hospital; a student transferred 16 Nov 2022 without notice to family or lawyer; Saman Yasin hospitalized 23 Jul 2023, two days after his prison audio message about torture; three actresses judicially \"diagnosed\" with mental illness in Jul 2023 for appearing unveiled; Roya Zakeri sent to Razi in Oct 2023 after filmed slogans; student Ahoo Daryaei transferred after a Nov 2024 undress protest | NGO documentation ([CHRI, 4 Nov 2024](https://iranhumanrights.org/2024/11/student-who-undressed-to-protest-irans-repressive-dress-code-joins-other-dissidents-forced-into-psychiatric-centers/); [Iran International](https://old.iranintl.com/en/iran/more-political-prisoners-being-moved-psychiatric-hospitals)); Amnesty reports electric shocks and beatings in such transfers | No independent access to records; state media's \"mentally ill\" labeling is itself part of the mechanism | VERIFIED (NGO) |\n\n**Batch 4 additions**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1968-RO-PARASCHIV | Romania, 1968–1989 | Securitate-directed psychiatric confinement; Decree 313 of 14 Oct 1980 on \"dangerous psychiatric patients\" | Worker Vasile Paraschiv quit the Party publicly in 1968, wrote to the Central Committee in 1971 and tried to found a free trade union; confined to psychiatric hospitals (1978 onward) and forcibly injected with neuroleptics without psychiatric symptoms; psychiatrist Ion Vianu, after emigrating in 1977, joined the Geneva Initiative and described the \"Ceaușescu doctrine\" that only a madman could imagine socialism perishing, with healthy people confined for months or years, not only around state visits; Poiana Mare hospital notorious for dissident detention | Securitate files at CNSAS; Presidential Commission (Tismăneanu) report 2006 names Paraschiv's 1978 case as the first proven in the West; US State Department cables (Reagan Library) record dissidents confined for political and religious beliefs; Amnesty reports (UK National Archives file) ([Radio Romania International](https://rri.ro/en/features-and-reports/the-history-show/political-psychiatry-in-communist-romania-id128387.html); [Hotnews, Andrei Ursu on Vianu (Romanian)](https://hotnews.ro/opinie-de-andrei-ursu-o-misiune-de-constiinta-lasata-de-ion-vianu-1527783); [Evenimentul Zilei (Romanian)](https://evz.ro/securitatea-lui-ceausescu-il-obliga-pe-vasile-paraschiv-sa-ia-un-tratament-care-sa-l-transforme-in-nebun-adevarat.html); [Reagan Library cables](https://www.reaganlibrary.gov/sites/default/files/2025-02/40-145-39146857-R05-021-2024_1.pdf)) | Prosecutors declined to charge Paraschiv's torturers (IICCR complaint 2010); no criminal finding | VERIFIED (secondary, local-language) |\n| 1963-CU-MAZORRA | Cuba, 1963–1980s | State Security interrogation (Villa Marista) followed by forensic-ward confinement at Havana Psychiatric Hospital (Mazorra) and Gustavo Machín (Santiago); electroshock | Brown & Lago documented 27–31 dissidents (sources differ) diagnosed with conditions such as \"apathy toward socialism\"; nurse Heriberto Mederos named by ten victims | Book-length investigation (Freedom House, 1991); JUDICIAL FINDING: a US federal jury convicted Mederos \\[corrected, Batch 18/D03: the offence was unlawful procurement of naturalization through false statements about persecution and Party membership; he died before sentencing; the verdict's necessary findings on electroshock are a LEAD — original wording follows\\] in 2002 of lying to immigration officials by denying he administered electroshock to political prisoners ([Cubanet](https://www.cubanet.org/htdocs/CNews/y02/ago02/09e6.htm); [Seattle Times, 1992](https://archive.seattletimes.com/archive/19920506/1490272/electroshock-torture-in-cuba-alleged----ex-political-prisoners-say-they-were-subjected-to-it); [JAAPL review](https://jaapl.org/content/20/2/237)) | Amnesty's researcher in 1992: no \"generalized practice\" found, though pressure on certain prisoners \"could have been used\"; Cuban authorities refused APA access to Mazorra | VERIFIED with DISPUTED scale |\n| 1963-AU-CHELMSFORD | Australia (NSW), 1963–1979; Royal Commission 1988–1990 | Private psychiatric hospital; barbiturate \"deep sleep therapy\" with ECT; false death certificates | 24 deaths from the treatment (other counts reach 85 including later suicides); only four deaths reached a coroner; complaints from patients and families produced coronial findings of no case to answer; Bailey himself was later secretly given the treatment by his partner | OFFICIAL FINDING: Slattery Royal Commission, 12 volumes, reports 17 and 21 Dec 1990 — irresponsible experimentation, fraud, gross negligence; treatment banned; coronial and medical-complaints law reformed ([Dictionary of Sydney](https://dictionaryofsydney.org/index.php/node/66876); [NSW State Archives description](https://researchdata.edu.au/agy-6764-royal-royal-commission/2754627); [Wellcome Collection film record](https://content.www.wellcomecollection.org/works/pn7pqjv7)) | Malpractice rather than political silencing; but a second documented case (with Lake Alice) of complaint channels failing for over a decade | VERIFIED |\n| 1977-ZA-APARTHEID-PSYCHIATRY | South Africa, 1970s–1980s | Racially segregated institutional confinement; private contractor (Smith, Mitchell & Co.) holding mostly Black long-stay patients; statutory restriction on publishing about institutions | WHO report *Apartheid and Mental Health Care* (MNH/77.5, 1977); APA Special Committee visit report (Am J Psychiatry 136:1498, Nov 1979) confirming \"grossly inferior\" care and \"needless deaths\" among Black patients; RCPsych special committee 1983; Anti-Apartheid Movement campaign for WPA expulsion; 1976 Mental Health Amendment Act criticized as restricting publication about institutions | International official reports ([AAM archive, \"Which way WPA?\"](https://aamarchives.org/archive/history/1980s/pro04-which-way-wpa/download.html); [Rhodes University thesis, 1989](https://researchrepository.ru.ac.za/items/df46dab0-b3e9-46b8-81b4-8717e8c67967/full); [BJPsych International review](https://www.cambridge.org/core/journals/bjpsych-international/article/reconciliation-and-psychiatry-in-south-africa/D61ADB45B24D13A383EB2C63F9C79914)) | Documented as structural neglect and segregation, not confinement of named dissidents; the publication-restriction claim is a LEAD to verify against the 1976 Act's text | VERIFIED (reports); LEAD (statute) |\n\n**Batch 5 additions — Southern Cone (an inverted pattern)**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1976-AR-PRISON-PSYCHIATRY | Argentina, 1976–1983 | Psychiatric labeling of legalized political prisoners inside penitentiaries; dismantling of the Federación Argentina de Psiquiatras; disappearance of mental-health professionals | Rafael and Melo's *Locura y suicidio en las cárceles de la dictadura* describes prison psychiatry recast as a control instrument: prisoners classified as \"inestables\", \"peligrosos\", \"paranoicos\" or \"desequilibrados\", which opened the door to isolation and medication, alongside induced despair the authors read as engineered suicide; the junta suppressed community psychiatry it considered leftist while adapting its techniques to promote \"Western and Christian\" values | Scholarly review ([UNPAZ, *Debates sobre Derechos Humanos*, Spanish](https://publicaciones.unpaz.edu.ar/OJS/index.php/debatesddhh/article/download/2208/2067)); [La Marea on Ramos's research (Spanish)](https://lamarea.com/2013/08/11/la-dictadura-argentina-utilizo-la-psiquiatria-para-esparcir-su-doctrina) | CONADEP (1984) documents disappearances, not psychiatric commitment; psychiatric labeling was ancillary to imprisonment | SUPPORTED (local-language) |\n| 1973-CL-PSYCHOLOGY-TORTURE | Chile, 1973–1990 | Psychologists and physicians advising interrogation and \"national social control\" policy; medical supervision of torture | Twelve interviews with psychologists trained 1973–1990, a Colegio de Psicólogos ethics file, and a dictatorship-era interview show direct and indirect contributions to interrogations; the Colegio Médico's ethics department (Díaz Paci) characterized medical supervision of torture as periodic assessment of the victim's capacity to endure it | Peer-reviewed ([Revista de Psicología, Universidad de Chile, 2024, Spanish](https://revistaschilenas.uchile.cl/handle/2250/247452?show=full); [Última Década, Spanish](https://ultimadecada.uchile.cl/index.php/RDP/article/download/71967/76848/289826)); Comisión Nacional sobre Prisión Política y Tortura (2004) recorded 38,254 cases of political imprisonment and torture ([Redalyc, Spanish](https://www.redalyc.org/pdf/967/96728593007.pdf)) | Chilean psychoanalysis's official histories minimize the period (Asclepio 2014); no documented pattern of confining dissidents in psychiatric hospitals | SUPPORTED (local-language) |\n| 1973-UY-BRITOS | Uruguay, 1973–1985 | Psychiatrist collaboration with military intelligence in prisons | Dolcey Britos, psychiatrist, documented as working with the military regime in the treatment of political prisoners; later subject of professional sanction | Comparative article ([Polis, Universidad de Los Lagos, Spanish](https://revistas.ulagos.cl/index.php/polis/article/download/751/910/659)) | Single secondary source here; SERPAJ *Uruguay Nunca Más* (1989) to open | LEAD |\n\n*Reading across the Southern Cone.* These three states had the Soviet template available and did not adopt it. Disappearance and prison were cheaper than diagnosis, and the professions that could have supplied diagnoses were themselves purged. The relevance to the mission is the mirror image: where psychiatry was not the state's tool, it was the state's target — and psychiatric labels still appeared, inside prisons, as a way to discount prisoners' resistance as pathology.\n\n**Batch 6 additions — Turkey, India, and the comparative control group**\n\n| Key | Country / period | Mechanism | What is documented | Finding or status | Contrary evidence / limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2016-TR-ATK-FORENSIC | Turkey, 2016–2025 | Council of Forensic Medicine (ATK) reports declaring sick or psychiatrically ill prisoners \"fit to remain in prison\"; prosecutors overriding release recommendations | Teacher Tuğba Y. reportedly lost her sanity under 24 days of interrogation (Jan 2017), was treated at Bakırköy, then jailed despite medical reports; academic Uysal's psychiatric referral and petitions ignored, ATK report 2024 kept him in prison; İHD counts 1,400+ sick prisoners; Human Rights Foundation of Turkey forensic reports document post-custody psychiatric collapse; Council of Europe torture report blocked from publication for nine years | NGO and advocacy reporting ([Stockholm Center for Freedom](https://stockholmcf.org/?p=71174); [Turkish Minute, 2017](https://www.turkishminute.com/2017/02/28/teacher-lost-sanity-detention-remains-jail-despite-doctors-reports/); [SCF on TİHV report](https://stockholmcf.org/report-turkish-man-in-police-custody-for-7-days-loses-mental-health/)) | The instrument is inverted: forensic authority denies rather than imposes confinement in hospital; sources are exile-advocacy outlets, to be cross-checked against TİHV and İHD originals | SUPPORTED (advocacy) |\n| 2001-IN-ERWADI | India (Tamil Nadu), 6 Aug 2001; Supreme Court 2001–2025 | Custodial neglect in faith-based asylum; chaining; non-implementation of the Mental Health Act 1987 | 28 chained inmates died in the Erwadi fire after NHRC warnings in May and July 2001; Supreme Court took suo motu cognizance (*In re Death of 25 Chained Inmates*, order 15 Oct 2001), found the 1987 Act \"not at all implemented,\" ordered unchaining and NHRC monitoring; owners sentenced to seven years (2007); Mental Healthcare Act 2017 replaced the 1987 Act; in Oct 2025 the Court again directed NHRC monitoring after chained inmates were found in Budaun; the 1946 Bhore Committee had already called mental hospitals \"mere detention centers\" | JUDICIAL FINDING and OFFICIAL monitoring ([Supreme Court order text](https://aicb.org.in/images/advocacy/SupremeCourt/In%20Re%20Death%20Of%2025%20Chained%20Inmates%20vs%20Union%20Of%20India%20And%20Ors..PDF); [CLPR case file](https://clpr.org.in/wp-content/uploads/2024/11/67_Asylum_Deaths_v_TN.pdf); [National Herald, 2026](https://www.nationalheraldindia.com/national/the-chains-have-gone-but-the-problem-persists); [IJMR review](https://ijmr.org.in/are-women-with-mental-illness-the-mentally-challenged-adequately-protected-in-india/)) | Welfare and custodial failure, not political silencing; included because it shows the complaint-channel failure (NHRC warned, nobody acted) in a non-political setting | VERIFIED |\n| 2019-EU-22-COUNTRY | 22 countries (Europe, Australia, New Zealand), 2008–2017 | Comparative involuntary-hospitalisation rates | Median 106.4 per 100,000; Austria highest at 282, Italy lowest at 14.5, Finland 218; England rose from 83.7 (2007–08) to 114.1 (2015–16); **no relationship between rates and any characteristic of the legal framework**, nor with demographic, economic or service indicators | Peer-reviewed ([Sheridan Rains et al., Lancet Psychiatry 6:403, 2019](https://discovery-pp.ucl.ac.uk/id/eprint/10072450); [open data set](https://data.mendeley.com/datasets/4y9tdf5xxf)) | Rates are not misuse; but the finding undercuts the assumption, implicit in every reform in section 6, that procedural safeguards govern how often detention is used | VERIFIED |\n| 2007-NORDIC-HIDDEN-COERCION | Denmark, Finland, Iceland, Norway, Sweden | Registration of coercion | Of 6,048 admissions reviewed, 3.3% (Finland) and 11.4% (Norway) of formally *voluntary* admissions were preceded by involuntary referral; published commitment rates therefore underestimate coercion to varying degrees; a 2026 comparative legal analysis finds \"considerable variation\" in Nordic statutes despite shared reputation for rights protection | Peer-reviewed ([BMC Psychiatry 7(S1):S141, 2007](https://bmcpsychiatry.biomedcentral.com/articles/10.1186/1471-244X-7-S1-S141); [Mijaljica, European Psychiatry 2026](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC13444966/)) | Measurement finding; mirrors HL v. UK on \"voluntary\" patients who are not free to leave, and California's voluntary/involuntary boundary | VERIFIED |\n\n*What the control group shows.* Across 22 jurisdictions with independent courts, counsel, and review tribunals, detention rates vary twentyfold and the law does not explain the variation. The implication for this record is that the safeguards catalogued in section 6 are necessary for individual cases but are not what determines the scale of coercion; practice, culture and the registration of what counts as \"voluntary\" do. That is consistent with the California finding that an audit of 120 cases found the criteria satisfied in every one while 7,400 people cycled through five or more holds.\n\n**Batch 7 addition — Goldwater, verified**\n\n| Key | Jurisdiction / date | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1964-US-GOLDWATER (verified) | US federal (S.D.N.Y.; 2d Cir.), 1964–1973 | Diagnostic discrediting without examination | *Fact* magazine (Sept–Oct 1964, \"The Unconscious of a Conservative\") mailed a questionnaire to 12,356 psychiatrists; 2,417 replied — 1,189 called Goldwater unfit, 657 fit, 571 declined; the APA medical director had warned the editor before publication that opinions without clinical examination were invalid; the cover headline ran in 48-point type | JUDICIAL FINDING: jury found actual malice, $1 compensatory and $75,000 punitive damages; affirmed, Goldwater v. Ginzburg, 414 F.2d 324 (2d Cir. 1969); certiorari denied, 396 U.S. 1049 (1970), Black dissenting; APA Annotation 7.3 (\"Goldwater rule\") adopted 1973 ([Am J Psychiatry 172:729, 2015](https://ajp.psychiatryonline.org/doi/full/10.1176/appi.ajp.2015.14111410); [JAAPL 44:226, 2016](https://jaapl.org/content/44/2/226)) | A defamation remedy against the publisher, not the psychiatrists; the rule is professional ethics without legal force, and the 2d Cir. opinion itself is still to be opened | VERIFIED (secondary) |\n\n**Batch 8 additions — a US territory, Belarus, Kazakhstan, and the querulant category**\n\n| Key | Jurisdiction / date | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2000-PR-LEY-408 | Puerto Rico, Ley 408-2000 (as amended) | Court-ordered temporary detention and involuntary admission | Any citizen over 18 with \"reasonable basis\" may petition the Court of First Instance (form OAT 1248/1964) for a temporary detention order of up to 24 hours for team evaluation, then court-ordered involuntary admission for up to 15 days, renewable; the petition must disclose the petitioner's economic or litigation interest; specialized mental-health courtrooms and a right to counsel throughout | Statute and judicial-branch materials ([Ley 408-2000 text](https://docs.pr.gov/files/ASSMCA/Leyes/LEY%20408-2000.pdf); [UPRM summary (Spanish)](https://www.uprm.edu/dcsp/wp-content/uploads/sites/159/2021/05/Ley-408-ley-de-salud-mental.pdf); [Poder Judicial, Salas Especializadas (Spanish)](https://poderjudicial.pr/Documentos/Educo/temas-legales/salud-mental/Servicios-Especializados-atender-asuntos-salud-mental.pdf); [Form OAT 1964, English](https://poderjudicial.pr/Documentos/formularios/OAT-1964-English.pdf)) | Structural contrast with California: a judge, not an officer or clinician, authorizes even the 24-hour stage; but any private citizen can set the process in motion. No retaliation case law located yet | VERIFIED (statute) |\n| 2020-BY-PUNITIVE-PSYCHIATRY | Belarus, 2020–2025 | Court-ordered compulsory psychiatric treatment in politically motivated criminal cases; secret trials; indefinite confinement; no parole, amnesty or pardon; incommunicado | Viasna counts at least 33 (Apr 2025) and 37 (Nov–Dec 2025) people sentenced to compulsory treatment among 7,840 political sentences; at least 21–25 still confined; one documented case: Matvei Bialyai, who struck the Government House doors with a hammer on 3 Mar 2021, ordered to compulsory treatment three months later and again in 2025 | OFFICIAL FINDING at UN level: Human Rights Council report on Belarus, 22 Apr 2025, para. 37; OHCHR experts' statement 24 Apr 2025 ([EUAA country guidance citing both](https://www.euaa.europa.eu/belarus-political-opposition-and-dissent/331-forced-psychiatric-treatment); [International IDEA tracker](https://www.idea.int/democracytracker/report/belarus/april-2025); [Pozirk/Viasna](https://pozirk.online/en/news/167095); [Nasha Niva on Bialyai](https://nashaniva.com/en/392912); [dissidentby.com case list](https://dissidentby.com/ru/political?page=93)) | The UN report itself notes secrecy makes it impossible to be certain in each case whether transfer was political or medical | VERIFIED (UN and NGO) |\n| 2009-KZ-MUKHORTOVA | Kazakhstan (Balkhash), 2009–2013 | Criminal charge for \"deliberately false complaint,\" then court-ordered psychiatric examination, \"delusional disorder\" diagnosis, repeated compulsory hospitalization | Lawyer Zinaida Mukhortova and three colleagues complained to the President in Sept 2009 that MP Nigmatullin had interfered in a civil case; a criminal case followed; a July 2010 forensic exam diagnosed delusional disorder; she was confined over eight months from Jan 2011; after she filed a complaint against the hospital's head doctor (2012), she was taken from her home by four police officers and medical staff on 9 Aug 2013; the Balkhash court's detention order cited her \"possibly querulant\" and \"litigious\" activity; an independent 2012 assessment found her sane; released 1 Nov 2013 | NGO and bar-association findings ([HRW, 15 Aug 2013](https://www.hrw.org/news/2013/08/15/kazakhstan-lawyer-forced-psychiatric-detention); [HRW World Report 2014](https://www.hrw.org/world-report/2014/country-chapters/kazakhstan); [ICJ statement, 3 Sep 2013](https://www.icj.org/wp-content/uploads/2013/09/Statement-Kazakhstan-030913.pdf); [Lawyers for Lawyers](https://www.lawyersforlawyers.org/kazakhstan-forced-psychiatric-confinement-of-zinaida-mukhortova/); [Open Dialogue Foundation](https://en.odfoundation.eu/?p=1245)) | Kazakh courts upheld the confinement (Karaganda regional court, 27 Sep 2013, in her absence); no domestic finding of retaliation | VERIFIED (NGO); the closest documented instance anywhere of *complaint → diagnosis → detention → complaint about detention → re-detention* |\n| 1904-ICD-QUERULOUS-PARANOIA | Psychiatric nosology, 1879–present | Diagnostic category: querulous (litigious) paranoia — Krafft-Ebing 1879, Kraepelin 1904; ICD-10 F22.8 *paranoia querulans* | The category fell out of use because, in the words of the standard account, it had been misused to stigmatize people pursuing valid grievances; Lester, Wilson, Griffin and Mullen revived attention in 2004 (\"Unusually persistent complainants,\" BJPsych 184:352) and 2006 (Behavioral Sciences & the Law 24), proposing management by complaints bodies and courts; a published reply, \"In defence of complainants\" (BJPsych 2004), warned that the diagnosis \"runs the risk of misuse by those who wish to use psychiatry as a manner of silencing criticism\" and that complaint merit is judged by each psychiatrist's prejudices | Peer-reviewed ([Cambridge Core, Lester et al. 2004](https://www.cambridge.org/core/journals/the-british-journal-of-psychiatry/article/unusually-persistent-complainants/83A0E0096877C744C449943DBC3697D5); [reply, \"In defence of complainants\"](https://core-prod.cambridgecore.org/core/product/4176C08F920312798A2B9C02E7A0F17E/core-reader); [Mullen & Lester 2006 abstract](https://zendy.io/title/10.1002/bsl.671); [Monash University Law Review on vexatious-litigant sanctions](https://www.austlii.edu.au/au/journals/MonashULawRw/2008/8.pdf)) | Lester et al. studied complaints officers' perceptions, not independently verified complaint merit (the reply's central objection); the category is in ICD-10 but not DSM-5 | VERIFIED — the one diagnostic category whose own definition is the act of complaining |\n\n*Why the querulant category matters to the whole record.* Every other diagnostic label in this record (sluggish schizophrenia, protest psychosis, drapetomania, personality disorder) had to be stretched to cover dissent. Querulous paranoia does not need stretching: its diagnostic content is persistence in seeking redress, and a Kazakh court used the word to authorize detention of a lawyer in 2013. For the California chapter, the open question is whether \"litigiousness\" or \"persistent complaints\" appears in 5150 applications or conservatorship petitions as evidence of disorder; that is a Batch 9 archival task.\n\n**Batch 9 addition — France**\n\n| Key | Jurisdiction / date | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 1913-FR-CLAUDEL | France, 10 Mar 1913 – 19 Oct 1943 | *Placement volontaire* under the loi du 30 juin 1838 — family-requested admission on one physician's certificate; the committed person acquired the legal status of a minor | Dr Michaux signed the certificate on 7 Mar 1913, five days after her father's death; her mother requested the placement and her brother Paul initiated it; admitted to Ville-Évrard, transferred to Montdevergues in Sept 1914; the 1914 admission certificate recorded \"systematic persecution delusion\"; biographers and psychiatrist Michel Deveaux record that doctors considered her releasable in the 1920s and that the family refused; the press at the time questioned the severity of the measure and the 1838 law; visitors described her as lucid; she stopped sculpting and died in the asylum | Museum chronology and standard biographies ([Musée Camille Claudel, \"1909–1943: period of confinement\"](https://museecamilleclaudel.fr/en/collections/camille-claudel-biography/1909-1943-period-confinement); [The Conversation, comparing the Spears conservatorship](https://theconversation.edu.au/britney-spearss-conservatorship-alludes-to-an-older-story-of-controlling-women-artists-164918)) | She had shown symptoms since at least 1905–1911; the dispute is over the 30-year duration against medical advice, not the initial admission; motives attributed to the family (protecting Paul's career, inheritance) are inference | DISPUTED on motive; VERIFIED on duration and family control |\n\n*What France adds.* The 1838 statute made family placement a routine legal form for 152 years (repealed 1990), and the Claudel record shows the pattern seen in Packard (1860), the Sōma incident (1883), the Duplessis orphans (1935–64), Korea's 2016 ruling and the Spears allegations: once a relative holds the key, release depends on the relative, and the confined person's own account of lucidity is weighed as a symptom. California's probate conservatorship shares this structure; its LPS conservatorship does not, because the conservator is normally the public guardian.\n\n**Batch 10 additions — California through channels 3 and 6**\n\n| Key | Jurisdiction / date | Channel | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- | --- |\n| 1962-CA-SF-FRANK | San Francisco, 1962–63 | 3 | Pre-LPS commitment; insulin coma and ECT | Leonard Roy Frank, 29, committed on a \"paranoid schizophrenia\" diagnosis and given about 50 insulin comas and 35 electroshocks; he later co-founded NAPA (Dec 1973) and edited *The History of Shock Treatment* | Survivor account and movement biographies ([Wikipedia with Andre and Warren citations](https://en.wikipedia.org/wiki/Leonard_Roy_Frank); [Street Spirit profile](https://freedom-center.willhall.net/pdf/leonardroyfrankstreetspirit.pdf)) | Family role in the commitment and the facility (Twin Pines, Belmont) to confirm from his own writings | SUPPORTED; LEAD on initiator |\n| 1972-CA-MNN-NAPA | San Francisco / Berkeley, 1972–1986 | 3 | Survivor press and organizing | *Madness Network News* founded 1972 by two women inmates of Agnews State Hospital, published to 1986; NAPA (Frank and Wade Hudson) organized protests that for a time stopped ECT in San Francisco; the movement began with the Insane Liberation Front (Portland, 1970) | Archival ([Mad in America history](https://www.madinamerica.com/2021/01/madness-network-news/); [Oskar Diethelm Library exhibit](https://oskardiethelm.omeka.net/exhibits/show/patient-perspectives-and--anti/-anti-psychiatry--communicatio)) | MNN's run (1972–86) is the single richest unsearched California case source; Batch 11 should read the issues for named 5150 and conservatorship cases | VERIFIED (archive located) |\n| 1982-CA-BERKELEY-MEASURE-T | Berkeley, Nov 1982 | 3 | Municipal ballot ban on ECT | Coalition to Stop Electroshock (Ted Chabasinski, d. 6 Nov 2025) qualified Measure T; passed by a wide margin; the APA spent $15,000 against it; Chabasinski's argument was that California's ECT consent law was so laxly enforced a ban was needed | Press and biography ([Wikipedia with NYT/Newsweek citations](https://en.wikipedia.org/wiki/Ted_Chabasinski)) | The ban was later struck down in court (Northern California Psychiatric Society v. City of Berkeley) — opinion to open | VERIFIED; LEAD on the overturning |\n| 2021-CA-ALAMEDA-DOJ | Alameda County, report 22 Apr 2021 | 6 and 2 | Federal civil-rights investigation | US DOJ found constitutional and federal-law violations at John George Psychiatric Hospital and Santa Rita Jail, including placement of people with serious mental illness in restrictive housing, non-therapeutic suicide-watch conditions, and failure to provide community-based services | OFFICIAL FINDING ([county's response in Babu v. Ahern quoting the report](https://rbgg.com/wp-content/uploads/Babu-Joint-Response-to-April-9-2021-Order-re-Santa-Rita-Jail-COVID-19-Response-04-28-2021-1378-1.pdf)) | Upgrades 2020-CA-ALAMEDA-DRC from ALLEGATION to a parallel OFFICIAL FINDING; the DOJ letter itself to open | VERIFIED (secondary) |\n| 2019-CA-KERN-SUICIDE-WATCH | Kern County, 2010s | 6 | Jail \"suicide watch\" isolation | Hundreds placed each year in single cells 24 hours a day with no treatment and a yoga mat; a county official quoted calling it \"punishment and humiliation\"; one hanging inside a watch cell | Investigative ([ProPublica / Prison Legal News, 2019](https://www.propublica.org/article/a-jail-increased-extreme-isolation-to-stop-suicides-more-people-killed-themselves)) | Harm, not retaliation; shows the instrument available for misuse | VERIFIED (reporting) |\n| 2014-CA-SANTA-BARBARA-SAFETY-CELL | Santa Barbara County | 6 and 2 | Jail \"safety cells\" | Disability Rights California found inmates with mental illness held in windowless safety cells \"three days at a time on a repeated basis,\" staff confirming placement was \"not temporary\"; the county called an outlier statewide | OFFICIAL advocacy report ([DRC via Santa Barbara Independent](https://www.disabilityrightsca.org/node/791)) | — | VERIFIED (secondary) |\n| 2021-CA-SLO-DOJ-AGREEMENT | San Luis Obispo County, 2018–2021 | 6 and 2 | DOJ settlement terms | Before disciplining a person with serious mental illness, staff must determine whether the conduct stemmed from illness; force and restraints \"prohibited as punishment or retaliation\" | OFFICIAL (DOJ agreement, [Noozhawk](https://www.noozhawk.com/?p=664571)) | A written safeguard against the exact misuse the record tracks; compliance data to follow | VERIFIED (secondary) |\n| 2025-CA-DOJ-IMMIGRATION | California immigration detention facilities, 2025 | 6 and 9 | State DOJ facility review | Detainees receiving mental health care disciplined at a higher rate at some facilities; mental-health reviews not conducted before discipline or segregation; a facility failed to report | OFFICIAL FINDING ([CA DOJ briefing slides](https://oag.ca.gov/system/files/media/care-comm-briefing-slides-052225.pdf)) | Correlation, not motive | VERIFIED |\n| 2015-US-NY-SUFFOLK-WATCH | Suffolk County, New York (E.D.N.Y.) | 6 and 1 | Jail suicide watch as discipline | Statistical analysis showed people in disciplinary housing were more likely to be placed and kept on suicide watch after clinicians ordered release; the plaintiff remained longer than 96% of comparable inmates | JUDICIAL FINDING: jury found the jail confined him to suicide watch without justification, as punishment, violating the Fourteenth Amendment ([NERA case summary](https://www.nera.com/experience/2015/pro-bono-statistical-analysis-of-prisoner-treatment-in-a-jury-tria.html)) | Case name and docket to confirm | VERIFIED (secondary); the first adjudicated finding in the record that a *psychiatric placement* itself was used as punishment |\n\n*What the first method run shows.* Two channels, one afternoon, one state: a new pre-LPS case, a 14-year archive of survivor-reported cases, a federal finding that upgrades an existing lead, and a jury finding on the adjacent instrument. The remaining channels (1, 2, 4, 5, 7, 8, 9, 10) have not yet been run on California; Batch 11 runs them before moving to Arizona.\n\n**Batch 11 additions — California through channel 1 (statute + retaliation in case law)**\n\n| Key | Jurisdiction / date | Mechanism | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2003-CA-SAN-LEANDRO-BIAS | San Leandro / Alameda County, 14 and 23 May 2003; 9th Cir. 28 Nov 2007 | 5150 ×2; PURPOSE question not reached | A pro se litigant with a pending matter before a judge was placed on two § 5150 holds nine days apart by the same officer; the second application recorded her statement that she would kill herself if the judge ruled against her; she was examined and released the same evening each time, then sued under § 1983 and Civil Code § 51.7 | JUDICIAL FINDING: probable cause existed; claims REJECTED ([*Bias v. Moynihan*, 9th Cir. opinion](https://cdn.ca9.uscourts.gov/datastore/opinions/2007/11/28/0516752.pdf)) | The litigation context is the trigger for the hold, exactly the complaint-to-hold sequence the record tracks, but the court's analysis stops at the officer's reasonable belief | VERIFIED (opinion) |\n| 2011-CA-SAN-DIEGO-NGUYEN | San Diego; S.D. Cal. 3:11-cv-02594; 9th Cir. No. 15-56996, 20 Mar 2017 | 5150; First Amendment retaliation claim tried | After a bench trial the court found officers had probable cause under § 5150, used reasonable force, and — on the retaliation count — accepted the officers' testimony that the plaintiff's speech was not a factor in the decision to detain | JUDICIAL FINDING, REJECTED on the merits ([9th Cir. memorandum](https://cdn.ca9.uscourts.gov/datastore/memoranda/2017/03/20/15-56996.pdf)) | **The only California case found in eleven batches in which retaliatory motive for a § 5150 hold was adjudicated rather than dismissed on immunity or state-action grounds.** The finding rests on officer credibility at trial; the district-court findings of fact are the document to open | VERIFIED (memorandum) |\n| 2000s-CA-FRESNO-LEFAY | Fresno; 9th Cir. | 5150 after a domestic call | Hold imposed after the husband reported being \"jumped on\"; summary judgment for the officer on probable cause affirmed | JUDICIAL FINDING, REJECTED ([*LeFay v. Panabaker*](https://caselaw.findlaw.com/court/us-9th-circuit/1762676.html)) | Illustrates private-party initiation (Mechanism 6) reaching the courts only on the probable-cause question | VERIFIED |\n| 2019-US-SCOTUS-NIEVES | US Supreme Court, *Nieves v. Bartlett*, 587 U.S. \\_\\_\\_ (2019) | Doctrine | Probable cause generally defeats a First Amendment retaliatory-arrest claim, with a narrow exception where similarly situated people not engaged in the speech are not arrested | JUDICIAL (doctrine) ([Justia](https://law.justia.com/cases/federal/us/587/17-1174/)) | Lower courts have applied the arrest framework to § 5150 detentions by analogy; the effect is that a retaliatory hold with probable cause is close to unreviewable in federal court, matching the state-law closure under § 5278 | VERIFIED |\n| 2007-2013-CA-BURBANK-DAHLIA | Burbank; 9th Cir. en banc 2013 | Adjacent: administrative leave after whistleblowing (no hold) | Detective reported colleagues' abuse of suspects, was threatened, then placed on leave; en banc court overruled *Huppert v. City of Pittsburg* and held such disclosures can be citizen speech | JUDICIAL (doctrine) ([Public Citizen](https://www.citizen.org/news/federal-appeals-court-reinstates-first-amendment-claim-of-whistleblower-police-officer/)) | No psychiatric instrument; included because it is the California doctrinal frame for officer-whistleblower retaliation that the Schoolcraft (NY) facts would be litigated under here | VERIFIED |\n\n*Reading across the channel-1 yield.* Four California holds reached a federal appellate court; in three the question of motive was never reached because probable cause was found; in one it was reached at trial and rejected on officer credibility. Combined with *Julian* (immunity, state action) and *Nieves* (doctrine), the California record now shows **\\[corrected, Batch 18/D05: overstated — Gonzalez v. Trevino (2024) narrows Nieves; the door is narrow, not shut\\] every available legal door to a retaliatory-hold finding closes before or at the motive question**. That is itself a Mechanism 3 finding: the procedural shadow is not only on the detained person but on the courts' capacity to see the pattern.\n\n**Batch 12 additions — California through channels 2 and 9 (complaint channel and its data shape)**\n\n| Key | What exists | What it produces | Gap for this record | Label |\n| --- | --- | --- | --- | --- |\n| CA-COPR-STRUCTURE | Each county has a Patients' Rights Advocate (W&I § 5500 ff.) with \"no direct or indirect clinical\" role, who investigates complaints in LPS facilities and reports Denial of Rights and ECT data upward to the California Office of Patients' Rights (COPR), operated under DHCS contract | A complaint path that exists at every LPS facility and is explained in county brochures ([San Bernardino DBH brochure](https://www.sbcounty.gov/uploads/DBH/2023/10/Patients%27%20Rights%20Brochure.pdf)) | The advocate's jurisdiction begins inside the facility; the § 5150 application itself — the moment of initiation — is outside it. A person whose grievance is *why they were brought in* has no designated recipient \\[corrected, Batch 18/D04: COPR handles intake, referral and county appeals but cannot change legal status; whether initiation complaints are accepted is untested\\] for that complaint | VERIFIED (structure) |\n| CA-IDR-FORMS | DHCS's Involuntary Detentions Data Report series is built from three quarterly county forms: DHCS 1009 (conservatorships established), DHCS 1010 (admissions by § 5150 category, later retitled \"Involuntary Treatment\"), and a third form covering denial-of-rights reports | Annual statewide and county counts and rates per 10,000, FY 2012-13 through FY 2021-22 ([FY14-15](https://www.dhcs.ca.gov/services/MH/Documents/FY14-15_InvoluntaryDetentionReport.pdf); [FY21-22](https://www.dhcs.ca.gov/services/MH/Documents/FY21-22-IDR.pdf)) | No field for initiator (officer, clinician, family), referral context, repeat holds, race, or complaint outcome; denial-of-rights data are counts by right denied, not narratives; DHCS notes some counties contract reporting to a sheriff's office or private entity that \"does not report data on the services provided\" | VERIFIED; LEAD on the third form's number and fields |\n| CA-REPORTING-BOUNDARY | Facilities report by county of admission, not county of origin; counties with joint agreements (Sutter/Yuba) are merged | Consistent counting of admissions | Cross-county holds (a common pattern when a person is taken from one jurisdiction to another facility) cannot be traced; a hold imposed in county A and received in county B appears only in B's total | VERIFIED |\n\n*Channel-9 reading.* The California complaint channel is real, staffed and lawful, and its outputs are designed to count rights denied *during* detention. Nothing in the reporting architecture can register a detention that was wrongly *begun*. This is the structural reason Batch 11's finding — every legal door closes before motive — is mirrored on the administrative side: there is \\[withdrawn, Batch 20/A04: overstated from the forms reviewed; county intake and appeal records untested\\] no form on which a retaliatory hold could be recorded even if one occurred. The parallel thread should treat the absence of California retaliatory-hold findings as an artifact of instrument design, not as evidence of absence.\n\n**Batch 13 — Arizona (channel 1)**\n\n| Key | Instrument | What is documented | Finding or status | Why it matters here | Label |\n| --- | --- | --- | --- | --- | --- |\n| AZ-36-520-INITIATION | A.R.S. § 36-520(A): \"any responsible individual may apply for a court-ordered evaluation\" of a person alleged to have a mental disorder and to be unwilling to be evaluated voluntarily; a screening agency then decides whether to petition | Statute and Arizona Supreme Court restatement ([*In re MH2023-004502*, 258 Ariz.](https://case-law.vlex.com/vid/re-mh2023-004502-1105632857)) | — | Private-party initiation (Mechanism 6) is the statutory default, not an exception; the only filter is the screening agency | VERIFIED |\n| AZ-2024-DIRECT-PETITION | 2024 session law (56th Leg., 2nd Reg. Sess., ch. 152, HB 2744) added a \"\\[SUPERSEDED, Batch 18/D02: this describes the introduced bill HB2744P; the enacted chapter keeps § 36-523(C)(2), filing only by the screening agency, and adds § 36-520(J) applicant notice of denial and reasons. Original wording:\\] direct petition for court-ordered evaluation\": if the screening agency declines to file, the applicant may petition the court directly; it also gives guardians and agents notice and standing in treatment proceedings | Session law ([azleg.gov](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf); [bill text](https://www.azleg.gov/legtext/56leg/2R/bills/HB2744P.pdf)) | — | Removes the \\[SUPERSEDED, Batch 18/D02 — the enacted law does not remove the gate; ranking withdrawn. Original wording:\\] clinical filter between a private complainant and the court; the first US jurisdiction in the record to *weaken* the professional gate in the 2020s. Arizona now sits beside Korea pre-2016 and the loi de 1838 in initiation design | VERIFIED |\n| AZ-2025-COE-AMENDMENTS | 2025 session law (57th Leg., 1st Reg. Sess., ch. 211, HB 2742) amended §§ 36-520, 36-530, 36-531: a screening agency may not refuse to process an application because no other services were tried; adds procedure for voluntary status during evaluation | Session law ([azleg.gov](https://www.azleg.gov/legtext/57leg/1R/laws/0211.pdf)) | — | Further lowers the threshold for processing applications | VERIFIED |\n| AZ-36-527-24H-NO-REMEDY | § 36-527(A): a person may not be held more than 24 hours in emergency custody unless a petition is filed; the court of appeals held an extra day's detention did not require vacating the later treatment order | JUDICIAL FINDING ([*In re MH 2006-002044*, 170 P.3d 280 (App. 2007)](https://syfert.com/caselaw/case.php?id=6603957)) | — | A time limit without a remedy — the Arizona analogue of California's § 5278 closure | VERIFIED |\n| AZ-36-533-EVAL-WAIVER | Treatment petitions require two physicians' affidavits after examinations; the court of appeals upheld an order where one physician's \"evaluation\" consisted of two failed interviews with an uncooperative patient, holding the objection waived | JUDICIAL FINDING ([*In re MH 2009-002120* (App. 2010)](https://www.omlaw.com/azapp-blog/postings/2010/involuntarily-committed-mental-health-patients-due-process-rights-are-not-violated-when-a-required/)) | — | Non-cooperation can satisfy the examination requirement; relevant to Mechanism 8 (refusal to engage read as symptom) | VERIFIED |\n| AZ-MOOTNESS | Orders routinely expire before appellate review; the Supreme Court decided *MH2023-004502* only under a mootness exception | JUDICIAL | — | Appellate oversight of initiation practices is structurally rare | VERIFIED |\n\n*Arizona status after channel 1:* **Lead, not Researched.** Channels 2 (Arizona Center for Disability Law, AHCCCS/OIG), 3 (survivor groups), 6 (Maricopa jail placements; Arizona State Hospital), 7, 8 and 9 (AHCCCS data fields) remain to run before the coverage index moves. No Arizona retaliatory-use allegation or finding has been located yet; the yield so far is design, not incident.\n\n**Batch 14 — Arizona (channels 2, 4, 6)**\n\n| Key | Date | Channel | What is documented | Finding or status | Limits | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2020-AZ-ASH-IOC-RETALIATION | Arizona State Hospital, IOC annual report 2020 | 2 | The statutory Independent Oversight Committee (A.R.S.-mandated) names as its \"primary concern\" that patients \"have consistently voiced concerns over retaliation from some staff after filing grievances\"; the IOC requested video of one retaliation incident and noted it has no investigative power of its own | OFFICIAL (oversight body) ([IOC 2020 report](https://ioc.az.gov/sites/default/files/2024-09/2020%20ASH%20IOC%20Annual%20Report.pdf)) | Patient-reported pattern, not adjudicated; the IOC's remedy is referral to the hospital's own complaints office | VERIFIED |\n| 2023-AZ-ASH-IOC-RETALIATION | IOC annual report 2022-23 (1 Nov 2023) and public meeting 19 Oct 2023 | 2 | \"Many patients believe there is a risk of retaliation if they file\" grievances; an anonymous letter traced to an active employee alleged fear of retaliation; at the October meeting the chair reported the committee reviewed nursing notes for a grievance case \"to see if there was any evidence of retaliation\" and found the grievance substantiated but could not assess post-grievance retaliation from the records available; a member stated that most grievances \"statistically lead to unfavorable outcomes in the form of an unsubstantiated claim, or retaliation\" | OFFICIAL (oversight body) ([IOC 2022-23 report](https://ioc.az.gov/sites/default/files/2024-10/DHS%20ASH%20IOC%20Annual%20Report%202022-23.pdf); [19 Oct 2023 minutes](https://ioc.az.gov/sites/default/files/2023-10/IOC_%20DHS_ASH%20IOC%20Meeting%20%282023-10-19%2018_03%20GMT-7%29.pdf)) | The IOC reads records the hospital chooses to supply; its own report says it cannot conduct investigations | VERIFIED |\n| 2023-AZ-SB1444-ANTI-RETALIATION | 2023 session, SB 1444 (State Hospital; administration; oversight) | 1 | Legislation addressing ASH administration and oversight; press reports a provision forbidding staff retaliation, which the IOC called \"a step in the right direction\" needing more | LEGISLATIVE ([Arizona Republic via Yahoo](https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html)) | Section text and effective date to open on azleg.gov | SUPPORTED; LEAD |\n| 2023-AZ-DRAZ-ACCESS-SUIT | Filed 12 Sep (2023); settled | 2 and 4 | Disability Rights Arizona (formerly Arizona Center for Disability Law), the PAIMI protection-and-advocacy agency, sued ASH and ADHS for choosing which patients it could speak to, listening to conversations, and withholding peer-review records on injuries and deaths; later settled for facility and patient access | SETTLEMENT ([DRAZ release](https://disabilityrightsaz.org/?p=37); [unsilenced.org index](https://www.unsilenced.org/?p=21972)) | Settlement terms to open | VERIFIED (secondary) |\n| 2023-AZ-ASH-DEATH-RECORDS | Feb 2023 | 9 | ADHS refused to release incident reports on two patient suicides, citing HIPAA and A.R.S. confidentiality; critics describe the department operating and overseeing the hospital as \"the fox watching the henhouse\" | Reporting ([Arizona Republic via Yahoo](https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html)) | A dataset-gap finding: death reports are the field not disclosed | VERIFIED |\n| 2021-AZ-AZCIR-INVESTIGATION | AZCIR / Amy Silverman, 2021 | 3 and 4 | Statewide investigation finds the *Arnold v. Sarn* settlement \"removed most accountability and transparency measures\"; crisis teams understaffed; \"street, treat, repeat\" short hospitalizations; \"claims of retaliation and isolation plague the state mental hospital for patients who file grievances\"; unlicensed boarding homes absorbing the overflow | Investigative ([Fund for Investigative Journalism summary](https://fij.org/?p=13742)) | Series itself to open | VERIFIED (secondary) |\n| 1989-AZ-ASH-CRIPA | 25 Sep 1989 – 14 Feb 1995 | 6 and 8 | DOJ CRIPA investigation of ASH found deficiencies in bodily restraints, medical care and psychiatric treatment (findings letter 14 Dec 1990); partial compliance by 1993; investigation closed 1995 | OFFICIAL FINDING ([Civil Rights Litigation Clearinghouse](https://clearinghouse.net/case/432/)) | Historical baseline for the same institution | VERIFIED |\n\n*Arizona status after channels 1, 2, 4, 6, 9:* **Researched (institutional); Lead (community holds).** The state's own oversight body has recorded, in two annual reports three years apart, that grievance-filing is believed by patients to invite retaliation, and has acknowledged it lacks the power to test the belief. That is Mechanism 9 (silencing the complaint channel) in an operating US facility, documented by a statutory body rather than an NGO. What Arizona still lacks in the record is any case on the *initiation* side — a court-ordered evaluation sought against a complainant — which channels 3 (survivor groups), 7 and 8 would be needed to surface.\n\n**Batch 15 — Texas (channels 1 and 2)**\n\n| Key | Instrument | What is documented | Finding or status | Why it matters here | Label |\n| --- | --- | --- | --- | --- | --- |\n| TX-573-PEACE-OFFICER | Health & Safety Code § 573.001–.002: a peace officer may apprehend without warrant on belief of mental illness and substantial risk of serious harm, and must immediately file a \"Notification of Emergency Detention\" on a statutory form stating the specific conduct relied on; 2013 HB 1738 added rights notices and barred facilities from requiring the officer's continued presence | Statute and bill analysis ([HB 1738 analysis, 83R](https://capitol.texas.gov/tlodocs/83R/analysis/pdf/HB01738S.pdf)) | — | The notification form is a written record of the initiating facts — a field California's § 5150 application also has, but which neither state aggregates; the Texas form is the channel-9 target document for any archival pass | VERIFIED |\n| TX-2015-SB359-FACILITY-HOLD | 2015 SB 359 \\[SUPERSEDED, Batch 18/D01: VETOED by Governor Abbott 2 Jun 2015; the text below describes the engrossed bill, never law. Original wording:\\] (84R) added § 573.005: hospitals, emergency departments and freestanding ERs may detain a person up to four hours without an officer or court order when a physician believes there is no time to file; a notice of detention goes in the medical record; subsection (h): such detention \"is not considered involuntary psychiatric hospitalization\" for the handgun-license disqualification in Government Code § 411.172(e) | Session law ([SB 359 engrossed](https://www.legis.state.tx.us/tlodocs/84R/billtext/doc/SB00359S.doc)) | — | A legislature designing an emergency hold *so that it leaves no firearm-record trace* — Mechanism 4 addressed by statute, in the opposite direction from California's § 8103 | VERIFIED |\n| TX-2023-2025-EXPANSION-BILLS | 2023 HB 5210 / SB 2287 / HB 3986 (88R) proposed letting non-physician mental health professionals file emergency-detention applications without a peace officer and extending facility temporary detention, with evidence to be presented to a court within four hours; 2025 HB 5463 (89R) revises the notification form | Bill texts ([HB 5210](https://capitol.texas.gov/tlodocs/88R/billtext/html/HB05210I.htm); [SB 2287](https://capitol.texas.gov/tlodocs/88R/billtext/pdf/SB02287S.pdf); [HB 5463](https://capitol.texas.gov/tlodocs/89R/billtext/pdf/HB05463I.pdf)) | — | Direction of travel is toward more initiators and longer no-order holds; enactment status of each to confirm | VERIFIED (texts); LEAD (enactment) |\n| 2020s-TX-AUSTIN-OPO-FALSE-REPORT | Austin Office of Police Oversight, formal complaint | A complainant alleged APD acted on \"a false report that I was suicidal with a gun\"; the mental health response officer was recorded declining to evaluate him (\"everyone's crazy tonight\"); OPO recommended the allegation for formal classification and cited §§ 573.001–.002 | OFFICIAL complaint record ([City of Austin OPO](https://austintexas.gov/node/82794)) | A documented instance of the third-party-report trigger (Mechanism 6) reaching a civilian oversight body; outcome to open | VERIFIED (complaint); outcome LEAD |\n\n*Texas status after channels 1–2:* **Lead.** Texas's record so far is design-level: a written initiating-facts form, a four-hour \\[proposed only — SB 359 vetoed, Batch 18/D01\\] facility hold deliberately kept off the firearm record, and pending expansion. Channels 3 (Texas survivor organizations), 4, 6 (Harris County jail, state hospitals — Rusk and Terrell have histories), 8 and 9 (HHSC emergency-detention data) remain. No Texas retaliatory-use allegation or finding is yet located.\n\n**Batch 16 — reverse sequence and the \"litigious as symptom\" question**\n\n| Key | Jurisdiction / date | Channel | Mechanism | What is documented | Finding or status | Label |\n| --- | --- | --- | --- | --- | --- | --- |\n| 2012-RU-BOLOTNAYA-KOSENKO | Moscow, May 2012 protest; trial 2013 | 6-reverse | LONG-COMMITMENT (compulsory treatment) | Mikhail Kosenko, a Bolotnaya Square defendant with a 12-year outpatient history, had his case severed from the others because investigators sought compulsory psychiatric treatment; a Soviet-era dissident testified he had not fought police; Memorial's Orlov called it a political trial | Court-ordered compulsory treatment; condemned by Memorial and Amnesty ([Wikipedia summary with Yaffa and press citations](https://en.wikipedia.org/wiki/Mikhail_Kosenko)) | VERIFIED (secondary); predates the 2016 start of the Russia rows — the register's Russian resurgence should now begin in 2013 |\n| 2005-US-3D-CIR-RICHARDS \\[re-keyed 2006-US-VI-RICHARDS, Batch 20/A01: opinion filed 23 Jan 2006, appeal from the District Court of the Virgin Islands\\] | US, 3d Cir. (non-precedential, 2005) | 1-reverse | COMPETENCY-EXAM (civil, Rule 17(c)); adversary-initiated | A pro se attorney-plaintiff; the defendant university \"suggested the District Court consider\" her competency; the magistrate judge ordered a psychiatrist to address it and appointed a guardian, stripping her of control of her own case; the Third Circuit took jurisdiction on the ground that denial of the right to proceed pro se \"injures dignity\" | JUDICIAL (interlocutory review granted) ([*Richards v. Duke University*, 3d Cir. 05-1170](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf)) | VERIFIED (opinion); **first row in the record where the opposing party in civil litigation initiated the psychiatric inquiry** |\n| 2011-US-2D-CIR-JAMES | US, 2d Cir. 2011 | 1-reverse | Post-detention discounting (Mechanism 8) | District court dismissed a pro se complaint with prejudice solely because the plaintiff had been adjudicated incapacitated in state court in 2003 and her guardians did not respond; her filings alleged a guardian held a financial interest adverse to hers; the Second Circuit vacated | JUDICIAL FINDING, REVERSED ([*James v. State of New York*](https://hallapproved.com/us/cases/ca2/2011/212975)) | VERIFIED; shows the guardianship record operating as a bar to the courthouse, with the person's own allegation against the guardian unheard |\n| 2018-US-MD-MONTGOMERY-VEXATIOUS | Montgomery County, Maryland; Court of Special Appeals unreported 0037s20 | 1-reverse | Vexatious-litigant order + guardianship + capacity evaluation | In a guardianship case the county health department petitioned for evaluation of the appellant's mental capacity; the court recounted her \"numerous frivolous, stream-of-consciousness pleadings,\" eight pro se motions, declared her a vexatious litigant, enjoined further self-represented filings, and after a competency hearing again found her unable to manage her affairs; fees were paid from her guardianship estate | JUDICIAL FINDING ([Maryland unreported opinion](https://www.courts.state.md.us/sites/default/files/unreported-opinions/0037s20.pdf)) | VERIFIED (opinion); the closest US analogue to the Mukhortova court's citation of \"litigious activity\" — filing volume recited in the same order that restricts filing and confirms incapacity |\n| 2012-US-3D-CIR-POWELL | US, 3d Cir. 2012 | 4 | COMPETENCY (civil) — contrary direction | A prisoner's psychiatric report put the district court on notice of possible incompetence; the court abused its discretion by not inquiring; reversed | JUDICIAL ([*Powell v. Symons*](https://www.njd.uscourts.gov/sites/njd/files/Powell.pdf)) | VERIFIED; Rule 17(c) running protectively |\n| 2016-US-6TH-CIR-DUBRULE | US, 6th Cir. 2016 | 4 | COMPETENCY (criminal) — contrary direction | \"The mere fact that a pro se litigant espouses a far-fetched, or even bizarre, legal-defense theory is insufficient to clear the high hurdle for incompetency\" | JUDICIAL ([JAAPL note on *United States v. Dubrule*](https://jaapl.org/node/8997)) | VERIFIED; the doctrinal counterweight to the Maryland and Richards rows |\n\n*Two patterns from Batch 16.*\n\n1. **Crowds get criminal law \\[WITHDRAWN as a rule, Batch 20/A04: the absence of holds in the protest searches run is a search result, not a pattern about crowds or individuals; kept here for provenance\\]; individuals get psychiatry.** The reverse search on US protest activists 2015–2026 returned arrests, charges and civil-rights settlements (Philadelphia $9.25M; Akron; St. Paul) and not one psychiatric hold. Every US psychiatric instance in the record is a single person embedded in an institution that owes them a duty of care — employer, department, family, court, hospital, jail. The welfare pretext (Mechanism 7) needs a custodial relationship to attach to. This predicts where to look: not protest records, but HR files, court dockets, guardianship registers, and institutional grievance logs.\n2. **In US civil courts the querulous marker runs through procedure, not diagnosis.** Rule 17(c) competency inquiries, guardian-ad-litem appointments, and vexatious-litigant orders perform the function ICD-10 F22.8 performs in Kazakhstan: the act of complaining becomes the evidence that the complainant cannot be heard. *Richards \\[corrected, Batch 20/A01, opinion re-read: Duke suggested the Rule 17(c) inquiry; Richards agreed to the psychiatric evaluation; the magistrate asked whether the text of her complaint showed \"delusional psychosis\"; the Third Circuit vacated the guardian appointment and held her competent to proceed pro se — a capacity-procedure case with appellate correction, not a retaliation finding\\]* adds that the adversary can start it; *James* adds that a prior adjudication can close the courthouse outright; the Maryland \\[Washburn v. McCarthy, 2021, per Edition 03/A03: clinical evaluations and other evidence supported the capacity decision; filing volume was not the whole basis — primary text not reopened in Batch 20\\] case adds that the costs can be charged to the person's own estate. Channel 6 now includes, for every US jurisdiction, the state's vexatious-litigant statute and its guardian-ad-litem rule as instruments to search.\n\n**Batch 17 — the interval table (channel 7 read across the record)**\n\nTiming is the one purpose-indicator that survives when motive is never adjudicated. The rows below are every case in the record where both the speech act and the psychiatric act are dated.\n\n| Key | Speech act | Psychiatric act | Interval | Who initiated | Outcome label |\n| --- | --- | --- | --- | --- | --- |\n| 2009-US-NY-SCHOOLCRAFT | Internal-affairs complaint and quota recordings | Forced removal to Jamaica Hospital psychiatric ward | Hours | NYPD superiors | SETTLEMENT |\n| 2003-CA-SAN-LEANDRO-BIAS | Pending ruling from the judge she was litigating before | Two § 5150 holds | Days before/around the ruling; 9 days apart | Same officer twice | REJECTED (probable cause) |\n| US-MD-BLAKE (Batch 2) | Testimony in a colleague's case | Fitness-for-duty exam ordered | 1 day after | Employer | JUDICIAL FINDING, $225,000 |\n| US-MI-DENHOF (Batch 2) | Testimony in sex-discrimination suit | Fitness-for-duty exam ordered | Shortly after testimony | Police department | JUDICIAL FINDING (6th Cir.) |\n| 2012-VA-RAUB | Facebook posts | Detention | Same day | Police / county | Petition dismissed as empty |\n| IR-YASIN (Batch 7) | Audio from prison describing conditions | Transfer to psychiatric hospital | 2 days | Prison authorities | NGO-VERIFIED |\n| 2012-RU-BOLOTNAYA-KOSENKO | Protest attendance | Case severed for compulsory treatment | Weeks (investigative stage) | Investigators | COURT ORDER |\n| 2013-KZ-MUKHORTOVA | Complaint about her own detention | Re-confinement; \"litigious activity\" cited | Weeks | Prosecutor / clinic | NGO-VERIFIED |\n| 2012-US-10TH-CIR-WITNESS | Scheduled testimony as sole prosecution witness | Involuntary commitment | 6 days before trial | Unknown (records withheld) | JUDICIAL (appellate note on withheld impeachment) |\n| 2018-US-MD-MONTGOMERY-VEXATIOUS | Eight pro se motions | Capacity evaluation petitioned; vexatious order | Same proceeding | County health department | JUDICIAL FINDING |\n\n*New row.* The Tenth Circuit \\[identified, Batch 20/A02: \\*United States v. Robinson\\*, 583 F.3d 1265 (10th Cir. 2009); the opinion states the informant was committed by his mother, who thought him suicidal; no suppression purpose appears; contrary authority \\*United States v. Hargrove\\*, 382 F. App'x 765 (10th Cir. 2010)\\] witness case ([JAAPL 40(2):291](https://jaapl.org/content/40/2/291)): the sole witness at a criminal trial had been involuntarily committed six days before testifying; the records showed heavy drug use and psychotic symptoms; the trial court declined to compel their production or a psychiatric examination; the appellate court observed that a jury aware of the records \"may well have rejected the witness's testimony.\" Who initiated the commitment and why are not in the opinion. Label: VERIFIED (secondary); LEAD on initiator.\n\n*Three patterns from the interval table.*\n\n1. **The shortest intervals belong to custodial initiators.** Hours and days appear where the initiator already holds the person — a police command, a prison, an employer. Where the initiator must go through a court or clinic (Kazakhstan, Russia, Maryland \\[no precise interval established, Edition 03/A03\\]), the interval stretches to weeks. Speed is a signature of custody, not of motive, so a fast hold is suspicious only in proportion to the initiator's prior power over the person.\n2. **The law converts a hospitalization into impeachment on its own.** Federal evidence doctrine treats a witness's \"insanity or mental abnormality,\" at the time of observing or of testifying, as provable on credibility. That means a hold placed before testimony has a guaranteed second effect without anyone intending it: even if the witness is released in time, the record is admissible against what they say. Mechanism 1 (credibility displacement) is therefore built into the rules of evidence, and the parallel thread should treat every pre-testimony hold as a two-instrument \\[WITHDRAWN, Batch 20/A04: a hospitalization does not automatically make a record admissible or a witness incredible; Robinson turned on its facts and Hargrove upheld refusal of records\\] event.\n3. **The complainant's own filings become the clinical exhibit.** In *Bias*, Mukhortova, and the Maryland \\[Washburn: clinical evidence also relied on, Edition 03/A03\\] case the documents that triggered the evaluation were the person's own pleadings. The archival task for California stated in the open questions — whether \"litigious\" or \"persistent complaints\" appears as evidence in § 5150 applications or conservatorship petitions — now has a US control: it demonstrably appears in guardianship and vexatious-litigant orders, so a null result in California would be meaningful rather than expected.\n\n**Batch 18 — corrections from the parallel thread's audit (edition 02, D01–D07; edition 01 register)**\n\n| Item | What this record said | What the primary source shows | Check performed here | Correction applied |\n| --- | --- | --- | --- | --- |\n| D02 — AZ-2024-DIRECT-PETITION | HB 2744 (2024 ch. 152) created a \"direct petition\" letting an applicant go to court when the screening agency declines | The enacted chapter adds § 36-504.01 (guardian/agent rights), a new § 36-520(J) requiring the agency to notify the applicant of a denial and, on request, give reasons, and § 36-523(C)(2): the petition \"may be filed only by the screening agency.\" No direct petition exists in the enacted text; the heading I relied on was in the *introduced* bill (HB2744P) and was dropped | Chapter 152 text opened in full this batch ([azleg.gov](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf)) | Row retitled **AZ-2024-CH152-APPLICANT-NOTICE**; claim reduced to: applicants gain notice of denial and reasons; the clinical gate stands. The \"loosest US initiation design\" ranking and the comparison to Korea pre-2016 and the loi de 1838 are **withdrawn**. Batch 13's lesson for the method: an introduced bill is not a session law — version status must be recorded on every statute row |\n| D01 — TX-2015-SB359-FACILITY-HOLD | SB 359 added § 573.005, a four-hour facility hold carved out of the firearm record | Governor Abbott vetoed SB 359 on 2 Jun 2015 ([veto statement](https://gov.texas.gov/news/post/governor_abbott_vetoes_sb_359); [LRL history](https://www.lrl.texas.gov/legis/billsearch/billdetails.cfm?billFileID=265810&from=advancedsearch)) | Veto accepted on the parallel thread's primary citations; not re-opened here | Row relabelled **TX-2015-SB359-VETOED**: a *proposed* hold designed to leave no firearm trace, never enacted. The Mechanism 4 observation survives as legislative intent of the bill's sponsors only. Whether a later bill enacted equivalent text is an open lead; the 2023 bills in TX-2023-2025-EXPANSION-BILLS now carry the same unresolved-status flag |\n| D03 — 1963-CU-MAZORRA (Mederos) | \"US federal jury convicted Mederos in 2002 of lying to immigration officials by denying he administered electroshock\" | DOJ describes the conviction as unlawful procurement of naturalization, involving false statements about persecution and Party membership; he died before sentencing ([USAB Jan 2006](https://www.justice.gov/criminal/hrsp/archives/2006/01-06USABulletin.pdf)) | Accepted | Row amended: the offence is naturalization fraud; what the jury necessarily found about electroshock requires the indictment, instructions and verdict form (LEAD) |\n| D04 — CA-COPR-STRUCTURE | \"A person whose grievance is why they were brought in has no designated recipient\" | COPR's own description includes intake tracking, referrals and county complaint appeals, while stating it cannot change legal status or secure release; its contract is with the Department of State Hospitals ([COPR page](https://www.disabilityrightsca.org/what-we-do/programs/california-office-of-patients-rights-copr)) | Accepted | Replaced with: the reviewed aggregate reporting does not establish a publicly auditable route from an allegation of retaliatory initiation to investigation, disposition and remedy. Whether county offices accept and act on such complaints is an empirical question for the county-pathway audit (queue item 4) |\n| D05 — 2019-US-SCOTUS-NIEVES and the Batch 11 reading | \"Every available legal door closes before or at the motive question\" | *Gonzalez v. Trevino* (20 Jun 2024, per curiam) rejected a reading of the *Nieves* exception that demanded near-identical comparators; vacated and remanded without deciding liability ([opinion](https://www.supremecourt.gov/opinions/23pdf/22-1025_1a72.pdf)) | Accepted | New row **2024-US-SCOTUS-GONZALEZ**; the Batch 11 sentence is softened to: in the four California § 5150 cases that reached the Ninth Circuit, motive was reached once and rejected; the doctrinal door is narrow, not shut, and its application to § 5150 seizures is untested after *Gonzalez* |\n| D06 — 2019-EU-22-COUNTRY | Called the Sheridan Rains study \"the control group for the whole record\" and said it shows safeguards do not govern coercion | It is an observational cross-national comparison of detention *incidence*; it measures neither wrongful nor retaliatory detention and cannot show that safeguards fail | Accepted | \"Control group\" language withdrawn; the row now says only that coded legal features were not associated with incidence across 22 countries, with definitional and implementation differences unexamined |\n| D07 — 1904-ICD-QUERULOUS-PARANOIA | Presented Lester et al. (2004) as the revival study without its method | The study relied on retrospective reports from Australian ombudsman staff; the complainants were not examined; the authors acknowledge the limit | Already noted in the row's limits column; strengthened | Row limits column now states the sampling design explicitly |\n| E01 — § 8103 (overview and Mechanism 4) | \"Firearm prohibition attaches automatically\" to a § 5150 hold | § 8103(f) attaches to a person taken into custody *and* assessed *and* admitted as a danger to self or others — not to every hold ([Justia text](https://law.justia.com/codes/california/code-wic/division-8/chapter-3/section-8103/)) | Accepted | Overview and Mechanism 4 reworded to \"qualifying admissions\" |\n| E02 — Doe v. Gallinot | \"Probable-cause hearing required before 14-day certification\" | The 1981 holding requires a hearing *after* emergency detention and no later than day seven ([657 F.2d 1017](https://law.justia.com/cases/federal/appellate-courts/F2/657/1017/395063/)) | Accepted | Timeline, register and safeguards rows reworded |\n| E03 — 2012-US-VA-RAUB civil outcome | LEAD | Fourth Circuit affirmed judgment for Campbell, 29 Apr 2015: no First Amendment causation shown, Fourth Amendment claim barred by qualified immunity; certiorari denied 16 Nov 2015 ([opinion](https://www.ca4.uscourts.gov/Opinions/Published/141277.P.pdf)) | Accepted | Row closed: REJECTED (civil); the earlier state release order stands as a separate JUDICIAL FINDING on the petition's deficiency |\n\n*What the audit changes in the method (added to the discovery section as correction 7).* **Version status is a field.** Every statute row must carry jurisdiction, session, bill number, version (introduced / engrossed / enrolled / enacted / vetoed), final action, effective date and the codified section as it stood at the event date. Two of the three design-level findings in Batches 13 and 15 failed this test. The parallel thread's twelve-field episode template (trigger → initiator → knowledge → asserted grounds → independent assessment → intervention → access → record consequences → review → remedy delivery → chilling effect → source independence) is adopted for all new register rows from Batch 19.\n\n**Channel 10 — keys reconciled with editions 01 and 02**\n\n| Parallel-thread key | Status in this record | Action |\n| --- | --- | --- |\n| US-FED-2022-PETITT (Petitt v. Delta; ARB 2021-0014) | Absent | **Add**: aviation whistleblower; ARB affirmed merits and back pay 29 Mar 2022, vacated front-pay and compensatory awards; compulsory evaluation treated as adverse action on the facts. Mechanism FITNESS-FOR-DUTY, JUDICIAL/ADMINISTRATIVE FINDING. Fits the Batch 17 interval table once the evaluation date is obtained |\n| UA-2015-ZAICHENKO-2 (ECHR 45797/09) | Absent | **Add**: 25 days' confinement for assessment in contempt proceedings; the only basis was insulting remarks about judges, with no medical opinion; Art. 5 and Art. 8 violations. **The strongest supranational row in the record for speech-as-sole-trigger** |\n| RU-2008-SHTUKATUROV (ECHR 44009/05) | Absent | **Add**: loss of capacity, confinement, counsel blocked; Art. 34 breach for preventing lawyer contact — Mechanism 9 adjudicated at ECHR level |\n| RO-2014-ATUDOREI (ECHR 50131/08) | Absent | **Add**: family-initiated hospitalisation; Art. 5 and 8 violations; control through medication without locked doors |\n| UA-2014-RUDENKO (ECHR) | Absent | **Add**: Art. 5 violation; hospital control over review |\n| FI-2012-X-V-FINLAND (ECHR) | Absent | **Add**: paediatrician; confinement and forced medication violations |\n| FR-2004-RL-MJD (ECHR 44568/98) | Absent | **Add**: restaurateur taken to a psychiatric unit after neighbour disputes; detention continued for want of the doctor's authority to release; Art. 5 |\n| GM-2003-PUROHIT-MOORE (ACHPR 241/01) | Absent | **Add**: first African Commission row; Lunatics Detention Act |\n| BR-2006-XIMENES-LOPES (IACtHR) | Absent | **Add** beside BR-BARBACENA; supervision closed 2023 without criminal accountability |\n| US-CA-2017-MUCH-LANGSTON (C.D. Cal. 2:16-cv-00863) | Absent | **Add**: Fourth Amendment § 5150 claim survived dismissal; counterexample to \"most end before discovery\"; later docket LEAD |\n| KR-2016-2014HUN-KA9 | Present as 2016-KR-CONSTITUTIONAL | Collision confirmed; official English summary link added |\n| NZ-LAKE-ALICE-HAKE-HALO | Present (1972-NZ-LAKE-ALICE) | Sub-row: letters withheld; messages in Niuean inside drawings — Mechanism 9 at the level of a child's mail |\n| UZ-2017-URLAEVA-COTTON | Present as LEAD (2001-UZ-URLAEVA) | Upgrade to VERIFIED (NGO) with the 1–23 Mar 2017 dates; separate the 2016 admission from the refusal to discharge |\n| IR-2023-HIJAB-PSYCHIATRIC-PENALTIES | Overlaps 2022-IR-WLF-PSYCHIATRIC | Add State Department 2023 reporting as a second stream; distinguish ordered outpatient care from inpatient transfer |\n| C03 Alice Paul (1917, D.C.) | Absent | **Add** to the timeline: psychiatric-ward placement during suffrage imprisonment; attempt to portray her as obsessed with Wilson (NPS account) — the earliest US federal instance of diagnostic discrediting of a political prisoner in the record |\n| C04 Canton Asylum (SD, 1903–34) | Absent | **Add** as institutional lead: federal asylum for Native Americans; 120 names; admission files to retrieve |\n| C02 Mary Todd Lincoln (1875) | Present as LEAD | Library of Congress letters located; motive unresolved |\n| C11 Belarus CAT/C/BLR/CO/5 (2018) | Partly present | Add 2018 concluding observations naming Postnov and Lapitski; BLR 3/2025 government reply dated 12 Jun 2025 unread |\n| C12 UN A/79/508 (2024) paras 46–52 | Absent | **Add** to the Russia rows: Special Rapporteur on examinations and institutions used against critics and complaining prisoners; Sokolov; Mikhailov's death; staff convictions |\n| D08 Denhof 2019 (6th Cir. 18-1406) | Present as 2007 only | Link as one litigation family: 2002 suit → jury → reversal → enforcement → 2019 reimbursement for recertification costs. Remedy-delivery field: still being litigated twelve years after the merits win |\n| D09 Winters v. Miller (2d Cir. 1971, 1975) | Absent | **Add** as a rights-of-treatment row (forced medication over religious objection), not a retaliation row |\n\n*Pattern from the reconciliation.* The parallel thread's independent supplement is heavily supranational (seven ECHR, ACHPR and IACtHR rows) where this record is heavily domestic; the overlap is small and the collisions all confirm. Supranational courts are the one forum in the record where *speech as the sole basis* has been adjudicated and found unlawful (Zaichenko). The two records together now show the same structure in three tiers: domestic courts stop at probable cause, oversight bodies stop at referral, supranational courts reach the basis of detention but not motive.\n\n## Synthesis: documented mechanisms of silencing and deterrence\n\nEight mechanisms recur across the record. For each, the evidence column says what kind of evidence supports it (CHILL-TESTIMONY, CHILL-RESEARCH, CHILL-OFFICIAL, or CHILL-INTERPRETATION) and whether purpose or only effect is shown.\n\n| Mechanism | How it operates | Strongest instances | Evidence type | Purpose or effect shown |\n| --- | --- | --- | --- | --- |\n| 1. Credibility displacement | A psychiatric record or label is used so that what the person says is heard as symptom rather than testimony | Ellsberg/Fielding (1971); Martha Mitchell (1972); military \"personality disorder\" discharges (HRW 2016) | Conviction and plea (Ellsberg); IG finding (military); interpretation (Mitchell) | PURPOSE shown for Ellsberg; EFFECT shown for military discharges; Mitchell purpose inferred |\n| 2. Removal at the moment of speech | Detention coincides with disclosure, complaint, or protest, removing the speaker from the scene | Schoolcraft (hours after his disclosures became known); Chinese petitioners confined around sensitive dates; Soviet pre-trial psychiatric transfer | Hospital records and settlement (Schoolcraft); NGO case files (China); Soviet admission (1989) | PURPOSE shown for USSR; ALLEGATION with settlement for Schoolcraft |\n| 3. The procedural shadow | A low-threshold, no-pre-hearing hold protected by immunity makes the downside of speaking asymmetric; the threat does the work without detention | § 5150 structure (§ 5278 immunity; Julian 2017); federal fitness-for-duty exams (MSPB 1.6%→6.1%); 36% of consumers citing fear of coerced treatment as a barrier to care (Swartz et al. 2003) | CHILL-RESEARCH (MSPB; Swartz); CHILL-OFFICIAL (1978 House subcommittee); CHILL-INTERPRETATION for § 5150 specifically | EFFECT shown by survey; purpose shown for FFD exams in 1978 finding |\n| 4. Durable record stigma | Collateral consequences attach automatically (firearm prohibition under Welf. & Inst. Code § 8103; discharge codes; employment), so a single hold deters future assertion of rights | § 8103 five-year prohibition after a 5150 admission; HRW *Booted* on benefits ineligibility | Statute (§ 8103); NGO documentation | EFFECT shown; purpose not required for the deterrent to operate |\n| 5. Diagnostic elasticity | Categories wide enough to absorb dissent, grievance, or non-conformity | \"sluggish schizophrenia\"; \"protest psychosis\"; drapetomania; \"adjustment disorder\" after assault | Historical and archival scholarship (Metzl; van Voren); Soviet admission | PURPOSE shown for USSR; effect shown elsewhere |\n| 6. Private-party initiation | Family members, employers, or conservators trigger or sustain the process; the state supplies the force | Packard (1860); Spears allegations (2008–2021); Donaldson (father's petition, 1957) | Jury verdict (Packard); Supreme Court finding (Donaldson); ALLEGATION only (Spears) | Mixed; shows the channel, not a general pattern |\n| 7. Welfare framing as pretext | \"Concern for the person's safety\" supplies a non-reviewable justification; the person's objection is read as symptomatic | Schoolcraft (police said he needed medical help); Raub (TDO petition empty of facts); Julian (investigating an assault on her) | Judicial finding of deficient petition (Raub); hospital record (Schoolcraft) | EFFECT shown; purpose contested |\n| 8. Post-detention discounting | After release, the person's prior and later statements are weighed against the fact of the hold | \"Martha Mitchell effect\" (Maher 1988); survivors' accounts in HRW reports; Spears' testimony met with a request to investigate its accuracy | Clinical literature naming the phenomenon; NGO testimony | CHILL-TESTIMONY; purpose not shown |\n\n**Evidence standard applied.** The parallel thread should note that only mechanisms 1, 2, 3 and 5 have any purpose-evidence, and none of it is Californian except the Ellsberg records burglary, which involved no detention. Everything else in California is effect-evidence or allegation. That asymmetry is partly structural: California's immunity and state-action rules end most cases before discovery, so retaliatory intent is rarely tested.\n\n**Batch 2–3 update to the mechanisms.** The worldwide pass strengthens four of the eight and adds one. Mechanism 2 (removal at the moment of speech) now has purpose-evidence outside the USSR: Saman Yasin's hospitalization two days after his prison recording about torture (Iran, 2023), the GDR practice of admitting psychiatric patients around state holidays as potential disruptors (Süß, from Stasi files), and Chinese petitioners confined before sensitive dates — the same timing logic in three unrelated systems. Mechanism 1 (credibility displacement) gains a judicial form: Iranian courts entering mental-illness \"diagnoses\" as sanctions against unveiled actresses (2023), and Vallejo-Nágera's 1938–39 studies supplying a scientific vocabulary for discounting Republican women. Mechanism 3 (procedural shadow) gains US jury findings that fitness-for-duty exams were ordered as retaliation for testimony (Denhof, Michigan 2007; Blake, Maryland 2011) — the first adjudicated retaliatory-purpose findings in the record. Mechanism 6 (private-party initiation) gains a constitutional court's statement that guardian–psychiatrist collusion \"often occurred\" (Korea 2016), Japan's founding Sōma inheritance case (1883), and the Duplessis fiscal motive. The new ninth mechanism is **silencing the complaint channel itself**: Lake Alice children shocked for complaining or running away, with professional bodies and ministries failing to act on complaints for 40 years (Royal Commission 2022), and Duplessis survivors' testimony met with demands for case-by-case proof — detention that discredits the person's later account of the detention.\n\n## Reforms, safeguards, and their documented limitations\n\nMost safeguards in the record protect against *wrongful* detention after the fact; almost none are designed to detect *retaliatory* detention, and the 72-hour stage in California has no hearing at all.\n\n| Safeguard | Jurisdiction and date | What it does | Documented limitation |\n| --- | --- | --- | --- |\n| Time limits replacing indeterminate commitment | California, LPS Act 1967/1969 | 72-hour evaluation, 14-day certification, conservatorship up to one year | No hearing at the 72-hour stage; Auditor 2020 found \\~7,400 LA County residents with 5+ holds in three years, 9% in intensive care — serial short holds substitute for the long ones LPS abolished |\n| Counsel and habeas on certification | California, Thorn (1970); Stats. 1969 ch. 722 | Appointed counsel visits all certified patients; habeas within two judicial days | Thorn itself noted sedated or distressed patients may not grasp the advisement, and the treating facility delivers it (\"role conflict\") |\n| Probable-cause (certification review) hearing | California, Doe v. Gallinot (9th Cir. 1981); § 5256 | Hearing officer review within days of 14-day certification | Hearing officers are often county-employed; low reversal rates reported anecdotally — Batch 2 to find published data |\n| Right to refuse medication (Riese hearing) | California, 1987; § 5332 (1991) | Involuntary patients keep the right to refuse antipsychotics absent emergency or a judicial incapacity finding | Emergency exception is broad; capacity hearings must be requested |\n| Patients' rights advocates | California, Welf. & Inst. Code § 5500 et seq. | County advocates receive complaints and investigate | Advocates are county-funded; no public data on complaints alleging retaliation located yet |\n| Historical-course evidence | California, AB 1424 (2001) | Decision-makers must consider the person's history and family input | Widens the basis for holds; critics argue it entrenches the label — the safeguard cuts both ways |\n| Audit and data reporting | California, Auditor Report 2019-119 (2020); SB 929 (2022) | Statewide hold data by county, demographics, sequence of holds | DOJ data cover only danger-based holds; 32 of 58 counties reported for 2023; no field captures the referral context (complaint, dispute, whistleblowing) |\n| Firearm-prohibition relief petition | California, § 8103(f) | Person may petition the court for relief from the five-year prohibition | Burden on the detained person; the prohibition attaches without any hearing on the hold's validity |\n| Civil damages | California, § 5278 immunity; Julian (2017); federal § 1983 | In theory, damages for detention without probable cause | Immunity for anyone acting with probable cause; no private right of action under LPS; private hospitals are not state actors; qualified immunity for officers — motive is almost never litigated |\n| Constitutional floors | US, O'Connor (1975), Addington (1979), Vitek (1980), Zinermon (1990) | Non-dangerous people cannot be held; clear-and-convincing standard; process on prisoner transfer and \"voluntary\" admission of the incompetent | Apply to longer commitment; the 72-hour hold sits beneath them in practice |\n| Limits on fitness-for-duty exams | US federal, 1978 subcommittee → OPM rules (5 C.F.R. § 339.301) | Agencies may order psychiatric exams only in narrow circumstances | MSPB surveys show retaliatory FFD exams rising 1992–2010 despite the rule |\n| Whistleblower discharge review | US military, Boards for Correction; DoD IG 2016 | Survivors may seek correction of discharge characterization | HRW: boards rarely correct; IG found 67% of relevant discharges undocumented |\n| Professional sanction | WPA Declaration of Hawaii (1977), Madrid (1996) | External condemnation; expulsion threat | Took 18 years (1971–1989) to produce an admission; no mechanism for individual cases |\n| Statutory reform without channel reform | China, Mental Health Law 2013 | Independent review and appeal rights | Ankang hospitals exempted; petitioners confined within months |\n| Supranational review | ECHR (Winterwerp 1979; HL v. UK 2004); UN CRPD Art. 14 | Court review of national detention practice; rights framing | No US domestic effect; CRPD not ratified by the US |\n\n## Contrary evidence and limits\n\nThe record contains as many rejected or unprovable claims as sustained ones. These entries stay in the register so the mechanism findings are not overstated.\n\n- **Official sampling found no misuse.** The 2020 State Auditor reviewed 120 California cases across three counties and found the LPS criteria appropriately applied in every one. The sample was random with respect to misuse, not targeted at complaints, so it neither proves nor disproves retaliatory use; it does show that routine holds, as documented, meet the criteria.\n- **Courts rejected the two California retaliation-type suits located so far on legal grounds, not on facts.** Julian (2017) lost on immunity, lack of a private right of action, and state-action doctrine. The absence of findings against the defendants is not a finding that the hold was proper, and vice versa.\n- **Prosecutors found no crime in the Schoolcraft hospitalization.** The Queens District Attorney concluded police and physicians acted reasonably in believing him an \"emotionally disturbed person\" and that the hospital made an independent medical judgment. The civil settlement established no liability. Yet the hospital's own notes recorded no significant symptoms, and the NYPD later confirmed the crime-statistics manipulation he reported.\n- **The Raub dismissal was procedural.** The judge found the petition empty of factual allegations; he did not find that the detention was aimed at Raub's speech. Some of Raub's posts included violent language (\"Sharpen up my axe; I'm here to sever heads\"), which is why police and crisis workers recommended evaluation. The later civil claim is a LEAD; reports indicate it failed on qualified immunity.\n- **Rosenhan is unreliable as evidence.** Cahalan's 2019 investigation found Rosenhan's own notes contradicted the published account and that only two pseudopatients could be verified, one of whom reported a positive experience that was excluded from the paper. Any argument resting on Rosenhan should be reconsidered.\n- **Frances Farmer's lobotomy is unsupported.** The 1940s commitment is documented; the lobotomy claim popularized in the 1970s has no record support. Flag as DISPUTED if the parallel thread uses it.\n- **Ezra Pound's competency finding is genuinely contested.** The finding that he was unfit for trial is a judicial record; whether it was medically accurate or a convenience to avoid a treason trial remains argued (Torrey 1984). This cuts against reading every competency finding as suppression.\n- **The military contested HRW's framing.** Defense officials disputed that personality-disorder discharges of assault survivors were retaliatory; the IG finding is about missing documentation, not motive.\n- **Legitimate emergencies look the same on paper.** The two 2008 Spears holds followed a custody standoff; the Julian hold followed an incident in which she was the reported victim of an assault. Nothing in the public record rules out that each hold was a reasonable emergency judgment at the time. The register records the allegations because they illustrate the channel, not because they are established.\n- **Chilling-effect numbers are perception data.** Swartz et al. (2003) measured self-reported fear as a barrier (36% of consumers surveyed); the MSPB figures count employees who say they experienced retaliation via exam. Neither measures whether a given exam or hold was in fact retaliatory.\n\n**Batch 19 — the hazard-report sequence: report → fitness inquiry → psychiatric action → fate of the report**\n\n\n\n**Scope and separation rules for this batch.** The sequence is tested, not assumed: each row records what supports retaliation and what supports a legitimate clinical or safety justification. Instruments are kept in separate categories and never merged: (A) employer fitness-for-duty or contractual medical evaluation; (B) military command-directed mental-health evaluation; (C) California § 5150; (D) civil commitment elsewhere; (E) guardianship; (F) threat without action; (G) referral to a professional regulator on fitness to practise, which is not psychiatric unless a record says so. Timing is evidence to investigate, not proof of motive. Settlements are not findings of liability.\n\n**Finding 1 — Petitt v. Delta Air Lines (Category A). The strongest adjudicated row in the record for this sequence.** Sources: [ALJ Decision and Order Granting Relief, 21 Dec 2020, 2018-AIR-00041](<https://www.oalj.dol.gov/DECISIONS/ALJ/AIR/2018/PETITT_KARLENE_v_DELTA_AIR_LINES_INC_2018AIR00041_(DEC_21_2020)_154529_CADEC_PD.PDF>) (the OALJ site refuses automated access; facts below are taken from the ARB's restatement of it); [ARB Order of Remand, ARB No. 2021-0014, 29 Mar 2022](https://www.dol.gov/sites/dolgov/files/OALJ/PUBLIC/ARB/DECISIONS/ARB_DECISIONS/AIR/21_014_AIRP.pdf) (read in full); [ARB No. 2022-0047, 26 Sep 2022](https://www.dol.gov/sites/dolgov/files/OALJ/PUBLIC/ARB/DECISIONS/ARB_DECISIONS/AIR/2022-0047-AIRP.pdf); [ARB September 2022 case summaries](https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/09_2022).\n\n| Field | Record |\n| --- | --- |\n| Hazard reported and evidence | 3 Nov 2015 email to Chief Pilot Phil Davis citing the FAA-regulated Safety Management Systems program and \"fear-based tactics\" inconsistent with a safety culture; 28 Jan 2016 a 45-page \"Assessment of Delta Air Lines 'Flight Operations' Safety Culture\" handed to Captains James Graham and Stephen Dickson (secondary sources say 43 pages; the ARB says 45). Delta conceded the Assessment Report was protected activity; the ALJ and ARB held the email was too. |\n| Who received it, when | Davis, 3 Nov 2015. Graham and Dickson, 28 Jan 2016. Graham sorted the report into operational issues, safety concerns and unequal treatment; Delta's Equal Opportunity department investigated, led by Kelley Nabors. |\n| Initiator and knowledge of the report | Graham, 9 Nov 2015, six days after the email: \"I also think we should consider whether a section 15 is appropriate.\" 16 Nov 2015, to Dickson: \"She could be a candidate for a section 15 after this goes through.\" Labor attorney Chris Puckett received the 9 Nov email the same day, contacted psychiatrist David Altman and sent him the Assessment Report. On 17 Mar 2016 Delta's Director of Health Services, Dr. Faulkner, recommended Section 15 ten minutes after Nabors's account; Graham accepted. |\n| Stated grounds | Nabors's account of an 8 Mar 2016 hotel meeting about the safety-culture allegations: tearful, \"frazzled\", fearful someone was \"out to get her\"; she had given documents to her mother to take to news outlets if anything happened to her; concern about a possible accident. Altman was told of memory issues. Dickson (deposition, per press) called the referral \"a sound course of action\". |\n| Independent assessment | Altman (company examiner) reported bipolar disorder and unfit to fly; she received it on 24 Dec 2016. A nine-doctor Mayo Clinic panel (pilot's examiner) unanimously found no bipolar disorder, no personality disorder, and no psychiatric disorder ever (16 Feb 2017). The FAA Northwest Regional Flight Surgeon wrote on 21 Aug 2017 that she remained eligible for a first-class medical. The neutral examiner, Dr. Andrew Huff, cleared her on 2 Sep 2017. Twenty-one months in the process. |\n| Escalation outside the contract | The agreement says the company examiner does not report to the FAA until Section 15 ends. After her recertification Faulkner, on Puckett's guidance, told an FAA regional flight surgeon Delta had information on a pilot with a \"permanently disqualifying condition\" (Mechanism 4: the record travels before the process finishes). |\n\n| Evidence against | OSHA initially found insufficient evidence. Nabors's description of the meeting. Dickson's stated reason. The ARB rejected the ALJ's rule that *any* Section 15 referral is adverse: a balance \"must be struck\" so that employers are not deterred from referring \"even when cautionary signs arise\". |\n| Fate of the safety report | Investigated by the Equal Opportunity department; Petitt presented it to divisional leaders on 27 Apr 2016 and saw Faulkner the same day. No DOL decision states what Delta did. Batch 20: the AP (21 Oct 2022) reports federal safety regulators looked into her allegations and found Delta was not counting time pilots spent commuting by air toward their maximum work day; Delta said it changed the policy. The regulator's own record (FAA) is the next document; training-record and SMS findings remain unknown. **LEAD.** |\n| Finding, stage, remedy | ALJ (21 Dec 2020): violation; back pay, front pay, $500,000 compensatory damages, publication to pilots. ARB (29 Mar 2022): **affirmed** protected activity, adverse action, contributing factor, failure of the same-action defense, and back pay ($52,522.03 or restored vacation); **vacated** front pay as legal error (a raise, not reinstatement) and the $500,000 for lack of evidentiary support; **remanded**, with leave to reopen the record on future lost earnings and on distress. Publication was not challenged; the ALJ ordered compliance on 6 Jun 2022; the Eleventh Circuit dismissed Delta's petition for lack of jurisdiction on 29 Aug 2022; the ARB denied Delta's interlocutory appeal and clarification motion on 26 Sep 2022 and dismissed a fee petition as premature on 21 Sep 2022. |\n| Implementation | Press reports say Delta sent the decision to pilots and the case settled in late 2022 with $confidential terms \\[corrected, Batch 20: AP, 21 Oct 2022 — settlement approved by ALJ Morris that day; terms confidential; her law firm said they were \"consistent with\" the 2020 ruling; no amount established\\]. Remand decision and settlement terms not seen: **LEAD**. |\n| Others less willing to report | No measured data. The ARB reasoned that immunising such referrals \"would deter employees from engaging in protected activity\" — a legal premise, not an observed effect. Press quotes the ALJ hoping publication would \"mitigate\" safety harm: exact passage **LEAD**. |\n\n*Correction carried forward (C19-01).* Summaries in this record and elsewhere that describe a sustained \"$500,000 award\" are superseded: the ARB vacated it. Any $payment \\[corrected, Batch 20: the settlement amount is confidential and not established\\] is reported as a settlement, which establishes no liability beyond the affirmed findings. The affirmed findings stand on their own.\n\n**Finding 2 — Diaz-Robainas v. Florida Power & Light, 92-ERA-10 (Category A, nuclear).** Sources: [NRC EA-96-051](https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/reactors/ea96051); [NRC conference record, FP&L presentation](https://www.nrc.gov/docs/ML1735/ML17353A755.pdf); [Secretary's decision (copy)](https://kkc.com/wp-content/uploads/2023/02/D-Rv.FPL_.pdf). An engineer identified technical safety issues on his projects (Feb–Aug 1991), complained of discrimination for doing so, and told management he would go to the media and the NRC. Director John Hosmer ordered a psychological fitness-for-duty evaluation on 30 Jul and 19 Aug 1991 and fired him on 19 Aug when he refused. FP&L's stated grounds: declining performance and behavioural observations, errors in a setpoint project, prior encouragement to use the Employee Assistance Program. No examination took place. The Area Director and the ALJ found for FP\\&L; the Secretary of Labor reversed on 19 Jan 1996, holding the order \"based solely on retaliatory animus\", and denied reconsideration on 15 Apr 1996. The NRC adopted the finding: Severity Level II, $100,000 civil penalty (the statutory maximum), no credit because FP&L had not reinstated him — the NRC noted non-compliance \"may itself have a chilling effect\". The Secretary also held the decision does not undermine the employer's duty to refer an employee whose fitness it questions. Batch 20, resolved from NRC Director's Decision DD-97-20 (62 FR 48116, 12 Sep 1997), n.5: because the Secretary remanded for remedy, his decision \"was not a final decision by DOL\"; the case settled before the ALJ ruled; FP&L paid the $100,000 penalty on 3 Dec 1996 (correcting Edition 03's caution that it was only proposed). The same decision reports NRC staff found no evidence of a chilling effect at FP&L from 89 allegations over two years — contrary evidence kept beside the finding. Employment settlement terms: **LEAD**. Fate of the technical issues: **LEAD**.\n\n**Finding 3 — the rules that already name psychiatric referral as a possible reprisal.**\n\n| Setting | Rule | What it does | Limit |\n| --- | --- | --- | --- |\n| US federal civil service | [5 U.S.C. § 2302(a)(2)(A)(x)](https://www.govinfo.gov/content/pkg/STATUTE-108/pdf/STATUTE-108-Pg4361.pdf), Pub. L. 103-424 (29 Oct 1994) | \"A decision to order psychiatric testing or examination\" is a personnel action that may be a reprisal | Not retroactive: [*Caddell v. DOJ*](https://caselaw.findlaw.com/court/us-federal-circuit/1092287.html) (Fed. Cir. 1996) — a 1991 psychiatric fitness order fell outside MSPB jurisdiction. Remedy is not automatic: [*Cerulli v. DoD*](https://cafc.uscourts.gov/opinions-orders/19-2022.opinion.6-9-2020_1601117.pdf) (Fed. Cir. 2020, nonprecedential) — a fire protection inspector ordered to a fitness exam and cleared; corrective action denied, affirmed |\n| US military | 10 U.S.C. § 1034; [DoDI 6490.04](https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/649004p.pdf) (reissued 27 Jul 2026); DoDD 7050.06 | No one may refer a service member for a command-directed evaluation as reprisal; two business days to consult a lawyer, IG or chaplain before a routine evaluation; reprisal referral is one of the IG's \"big three\" | Substantiation counts not yet located: **LEAD** |\n| US nuclear | 10 CFR 50.7; 10 CFR 73.56 behavioural observation; Part 26 fitness for duty | Retaliatory referral is a licensee violation (EA-96-051) | The same programs oblige referral; no rule separates the two in advance |\n| US rail | 49 U.S.C. § 20109(c)(2) | Fitness-for-duty safe harbor | ARB (*Santiago*): a retaliatory refusal is not \"pursuant to\" medical standards |\n| US aviation | AIR 21, 49 U.S.C. § 42121; *Petitt* (ARB 2022) | A compulsory evaluation is adverse when retaliatory, pretextual, in bad faith or harassing; factors include length, routine vs. bad-faith, and comparator treatment | Case by case; earlier dicta in *Estabrook v. FedEx* (ARB 2019) said the opposite |\n| California healthcare | Health & Safety Code § 1278.5; [*Fahlen v. Sutter*](https://scocal.stanford.edu/opinion/fahlen-v-sutter-central-valley-hospitals-34291) (Cal. 2014) | A physician may sue for retaliation without first overturning the hospital's peer-review decision | The instrument there is peer review (Category G), not psychiatry |\n\n**Finding 4 — the NRC's chilled-work-environment record is established, but it is not psychiatric.** The NRC defines a chilled work environment as one \"where the willingness of a group of employees to report safety or regulatory concerns is inhibited\" ([NRC letter to USUHS/AFRRI, 18 Mar 2020](https://www.nrc.gov/docs/ML2007/ML20070K841.pdf)), under the [1996 Policy Statement](https://www.nrc.gov/docs/ML0105/ML010520148.pdf) (61 FR 24336) and RIS 2005-18. It measures chilling at group level through inspections, allegation trends and Chilling Effect Letters: AFRRI 2018–20 (staff believed Inspector General investigations were opened partly because they raised concerns — an investigative instrument, not a psychiatric one); [CB&I Lake Charles 2013](https://www.nrc.gov/docs/ML1309/ML13092A077.pdf) (19 chilling-effect concerns, 4 substantiated); VA Salisbury 2010; Alaska DOT&PF confirmatory order 2004. **None of the reviewed letters involves a psychiatric instrument.** The only psychiatric-specific nuclear finding located is Diaz-Robainas. The established chilling effect and psychiatric retaliation are therefore separate rows; the second is documented in individual adjudications, the first in group measurement, and no source yet joins them with data.\n\n**Finding 5 — healthcare and the UK.** [*Bichai v. Dignity Health*](https://www4.courts.ca.gov/opinions/archive/F078658.PDF) (Cal. App. 2021): a physician who advocated for a patient completed the UCSD PACE program, which found him \"fit for duty without accommodation\" (Jan 2017); whether PACE included a psychiatric component is unread: **LEAD**. The [Francis Freedom to Speak Up review](https://hcpc-uk.org/globalassets/meetings-attachments3/council-meeting/2015/march/enc-09---hcpc-response-to-the-report-of-the-freedom-to-speak-up-review) (Feb 2015; over 19,500 survey responses) found referrals to professional regulators were sometimes made in retaliation and asked regulators to test referrals for that — Category G, kept separate from psychiatry.\n\n**Case register — Batch 19**\n\n| Key | Setting | Hazard | Instrument (category) | Initiator; knew of report? | Independent assessment | Finding, stage, remedy | Fate of hazard | Status |\n| --- | --- | --- | --- | --- | --- | --- | --- | --- |\n| US-FED-2015-PETITT | Airline (Delta), WA/GA | Fatigue, training records, SMS culture | Section 15 psychiatric evaluation (A) | VP Flight Ops Graham, labor counsel Puckett, DHS Faulkner; yes | Mayo panel and neutral examiner contradicted company psychiatrist | ARB affirmed violation and back pay; front pay and $500k vacated; remanded; settlement approved by ALJ 21 Oct 2022, terms confidential | Not stated in decisions | VERIFIED (merits, settlement fact); LEAD (terms, regulator record on commute-time finding) |\n| US-FL-1991-DIAZ-ROBAINAS | Nuclear (Turkey Point) | Technical safety issues | Psychological fitness order; firing for refusal (A) | Director Hosmer; yes | None — refused | Secretary of Labor found retaliation (reversing ALJ), non-final; settled on remand; NRC $100,000 penalty paid 3 Dec 1996 | Not stated | VERIFIED (finding, penalty paid, settlement); LEAD (terms, fate of hazard) |\n| US-FED-1991-CADDELL | DOJ | Disclosure content unread | Psychiatric fitness exam (A) | Agency | Unread | No jurisdiction: pre-1994 | Unread | LEAD |\n| US-FED-CERULLI | DoD fire protection | Unread | Fitness-for-duty exam (A) | Agency | Cleared | Corrective action denied; affirmed 2020 | Unread | REJECTED (claim) |\n| US-CA-2017-BICHAI | Hospital, CA | Patient care advocacy | PACE assessment (A or G — unresolved) | Hospital | Found fit | Appellate ruling on pleadings | Unread | LEAD |\n| US-NRC-2020-AFRRI | Military research reactor | Nuclear safety, regulatory | IG investigations (not psychiatric) | Management | NRC inspections | Chilled environment identified | Open in 2020 | VERIFIED — chilling, not psychiatric |\n| US-LA-2013-CBI | Nuclear fabrication | Safety concerns | Chilled environment (not psychiatric) | Management | NRC | Chilling Effect Letter; confirmatory order | Corrective program | VERIFIED — chilling, not psychiatric |\n| UK-2015-FRANCIS | NHS England | Patient care | Regulator referral (G) | Employers | Review | Recommendations; national guardian | Mixed | SUPPORTED (pattern) |\n\n**Reading across Batch 19.**\n\n1. *The adjudications decide the employment question, not the safety question.* In both verified rows the tribunal settles whether the psychiatric step was retaliation; neither decision I read says what became of the hazard. That absence is a Channel 9 finding: no reviewed forum records the fate of the original report.\n2. *The legitimate-justification evidence is real and is the same evidence in both directions.* Distress, fear and talk of going to the press were the stated grounds in *Petitt*; threats to go to the NRC and the media were protected activity in *Diaz-Robainas*. A reporter's alarm about a hazard and an institution's alarm about the reporter can be read from one meeting. The ARB's factors — length, routine versus bad faith, comparators — are the tests that separate them, and no reviewed program records comparator data.\n3. *A neutral tie-break can work and still do the harm.* *Petitt*'s contract had a pilot examiner and a neutral examiner; they cleared her, but only after 21 months, a diagnosis delivered on Christmas Eve, and a report to the regulator before the process ended.\n4. *Psychiatric retaliation and chilling are measured by different bodies.* Individual findings come from DOL, MSPB and IGs; group chilling comes from the NRC. The record has no study connecting a psychiatric referral to a measured fall in reporting.\n\n**Batch 20 — reconciliation with Compilation Edition 03 (received 7 Oct 2026)**\n\nEdition 03 is a parallel compilation (Parts A–E). It is treated as a cross-check (channel 10), not as corroboration: where it and this record agree, the agreement counts only as far as one of us opened the primary source. Each item below says which.\n\n**Edition 03 corrections, checked and applied in place**\n\n| Item | Edition 03 says | Batch 20 check | Applied |\n| --- | --- | --- | --- |\n| A01 Richards | Filed 23 Jan 2006; Virgin Islands; exam agreed; guardian vacated | [Opinion](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf) read in full: confirmed. Adds that the magistrate asked whether the *text of the complaint* showed \"delusional psychosis\", and the court held a guardian protects the incompetent person, \"not the defendants\" | Row re-keyed 2006-US-VI-RICHARDS; Batch 16 pattern 2 amended |\n| A02 Tenth Circuit witness | *United States v. Robinson*, 583 F.3d 1265; mother-initiated; Hargrove contrary | [Opinion](https://www.ca10.uscourts.gov/sites/ca10/files/opinions/01018295738.pdf) excerpt confirms the mother committed the informant believing him suicidal | Row identified; \"two-instrument\" pattern withdrawn |\n| A03 Washburn | Clinical evidence, not filing volume alone | Primary not reopened this batch | Applied as Edition 03's correction, marked unverified here |\n| A04 universal claims | Withdraw five general claims | Agreed: each rests on bounded searches | \"Crowds/individuals\", \"no form\", \"two-instrument\", \"safeguards do not\" marked withdrawn; \"every door\" was already corrected in Batch 18 |\n| A05–A08 | Texas, Arizona, § 8103, Gallinot, Sheridan Rains, Lester, Mederos | Same as Batch 18 D01–D07, E01–E02 | Already applied |\n| A09 Malik | Contract breach succeeded; whistleblowing detriment (GMC email) succeeded; automatic unfair dismissal failed | Not in this record before; tribunal judgment not reopened | New row below, Edition 03 status |\n\n**Corrections this batch makes to Edition 03**\n\n1. *Diaz-Robainas, penalty.* Edition 03 warns not to call the $100,000 penalty paid. The NRC's [Director's Decision DD-97-20](https://www.govinfo.gov/content/pkg/FR-1997-09-12/pdf/97-24220.pdf), footnote 5, states FP&L paid it on 3 Dec 1996. The same footnote confirms the Secretary's finding was not a final DOL decision and that the case settled before the remand ruling.\n2. *Petitt, settlement.* Edition 03 cites the AP report; its fuller text says terms were confidential and adds the only located account of what happened to the hazard: regulators found duty time excluded pilots' air commutes and Delta said it changed the policy ([AP via WJXT](https://www.news4jax.com/news/politics/2022/10/21/delta-air-settles-with-pilot-who-raised-safety-concerns/)).\n3. *Petitt, September 2022 dismissal.* Edition 03 says the 21 Sep 2022 document was not retrieved. The ARB's own September 2022 summary (read in Batch 19) states it dismissed a premature attorneys'-fee petition.\n\n**Part C cases carried in from Edition 03 (channel 10; primary sources not reopened in Batch 20 unless stated)**\n\n| Key | Setting | Instrument category | Edition 03's account | Status here |\n| --- | --- | --- | --- | --- |\n| 1983-US-TN-DEFORD | TVA Sequoyah, QA engineer | Not psychiatric instrument: depression and hospitalization described as *consequences* of retaliation | Sixth Circuit affirmed retaliatory transfer; remedy remanded | Cross-thread; keep out of the instrument count |\n| 2002-US-FED-MEEKER | USPS (EEOC appeal 01A12137) | A — required counseling after doctors found him fit | EEOC: requirement lacked job-relatedness or business necessity; no safety-report origin shown | Cross-thread; adjacent |\n| 2021-UK-MALIK | Psychiatric hospital, England (ET 2403141/2018) | G — medical director's email to the GMC liaison | Detriment for protected disclosures found; automatic unfair dismissal failed; some claims out of time | Cross-thread |\n| 1996-US-CT-DELCORE | CL&P v. Secretary, 85 F.3d 89 (2d Cir.) | Not psychiatric — settlement terms restricting contact with the NRC | Proposing them was prohibited discrimination | Cross-thread; Mechanism 9 analogue |\n| 2015-UK-GMC-HOOPER | GMC review | G — safeguard | Recommends checking whether referred doctors raised safety concerns | Cross-thread; implementation unknown |\n| 1994-US-MI-MANDREGER | Detroit Edison, 88-ERA-17 | Mixed | Hostility to NRC reporting found; employer would have removed him anyway | Cross-thread; contrary-outcome row |\n| 1998-US-GRIFFIN | Consolidated Freightways, 97-STA-10/19 (ARB) | A — psychological scrutiny after a letter to an ALJ and deposition statements | ARB rejected retaliation: independent observations justified the evaluation | Cross-thread; key contrary row — litigation documents used in a fitness assessment *without* a retaliation finding |\n\nEdition 03 leads carried unchanged: *Floyd v. Arizona Public Service* (90-ERA-39); *Freels v. Lockheed* (95-CAA-2); *Smith v. Esicorp* (93-ERA-16).\n\n**New lead from Batch 20 primary reading: 1989-US-FL-SAPORITO.** DD-97-20 records that in *Saporito v. FP&L* (89-ERA-7/17) the Secretary held in 1994 that an employee who refuses to reveal safety concerns to management and insists on going to the NRC is engaged in protected activity, and remanded. At a July 1997 NRC meeting Saporito said two FP&L officials testified that union officials told management he could \"potentially sabotage the plant\", and that his site access was revoked as a result. That is Saporito's account of DOL testimony; no final DOL finding existed in 1997. Category: access authorization (trustworthiness), adjacent to A. **LEAD**: the remand decision and the hearing transcript.\n\n**Reading across Batch 20.** The two strongest rows now each have an outcome document, and both outcomes are settlements — after findings that were affirmed (Petitt) or adopted by a regulator (Diaz-Robainas). Griffin and Mandreger show the same fact pattern ending the other way. The NRC's 1997 refusal to infer a chilling effect without evidence is itself useful: it states the standard this record must meet.\n\n## Annotated bibliography\n\n\"Opened\" means the page was read in this batch; \"cited\" means a standard citation given from knowledge and still to be opened. The parallel thread can deduplicate on the key in brackets.\n\n**California primary and official sources**\n\n- [Thorn v. Superior Court (1970) 1 Cal.3d 666](https://scocal.stanford.edu/opinion/thorn-v-superior-court-27536) — opened. Full opinion; quotes original § 5150 text, the 1966 Subcommittee Report, and the Mrs. Green facts. \\[THORN-1970\\]\n- [California State Auditor, Report 2019-119 (28 Jul 2020)](https://information.auditor.ca.gov/reports/2019-119/index.html) — opened (summary and index). Sample findings, repeat-hold figures, data limits. \\[AUDIT-2020\\]\n- [DHCS, California Involuntary Detentions Data Report FY2017-18](https://www.dhcs.ca.gov/Documents/CSD_YV/MHSA/IDR/FY17-18-IDR-Report.pdf) — opened via search extract; statewide 72-hour counts. Column assignment to be re-checked against the full table. \\[DHCS-IDR-1718\\]\n- [DHCS, 2025 Lanterman-Petris-Short Act Annual Report (calendar 2023 data)](https://www.dhcs.ca.gov/ru/formsandpubs/forms/Documents/2025-LANTERMAN-PETRIS-SHORT-ACT-ANNUAL-REPORT.pdf) — opened via extract; 32 of 58 counties reporting. \\[DHCS-LPS-2025\\]\n- [Assembly Judiciary and Health Committees, LPS Background Paper](https://ajud.assembly.ca.gov/sites/ajud.assembly.ca.gov/files/LPS%20Background%20Paper.pdf) — opened via extract; national pre-history (1951 NIMH Draft Act, 1964 Ervin Act). \\[ASM-LPS-BACKGROUND\\]\n- [Disability Rights California, History of the LPS Act](https://www.disabilityrightsca.org/system/files/file-attachments/HistoryoftheLPSActAccessibleJuly14202.pdf) — opened via extract; bill history (AB 1220, SB 677), later amendments. \\[DRC-LPS-HISTORY\\]\n- [Senate Judiciary analysis, AB 2242 (2022)](https://sjud.senate.ca.gov/sites/sjud.senate.ca.gov/files/20212022_0_ab2242_06-27-2022_santiago_judiciary_spc_140370.pdf) — opened via extract; 72-hour holds \\~80% of all LPS holds in FY2018-19. \\[SJUD-AB2242\\]\n- [Julian v. Mission Community Hospital (2017) 11 Cal.App.5th 360 — Justia summary](https://civilrightsopinions.justia.com/2017/05/02/julian-v-mission-community-hospital) — opened; [Horvitz & Levy summary](https://www.horvitzlevy.com/?p=57876) — opened. Full opinion still to be read. \\[JULIAN-2017\\]\n- Doe v. Gallinot, 657 F.2d 1017 (9th Cir. 1981) — cited. \\[DOE-GALLINOT\\]\n- Riese v. St. Mary's Hospital and Medical Center (1987) 209 Cal.App.3d 1303 — cited. \\[RIESE-1987\\]\n- Conservatorship of Roulet (1979) 23 Cal.3d 219 — cited. \\[ROULET-1979\\]\n- People v. Triplett (1983) 144 Cal.App.3d 283 — cited; probable-cause standard for peace-officer holds. \\[TRIPLETT-1983\\]\n- Welf. & Inst. Code §§ 5150, 5250, 5256, 5278, 5332, 5500, 8103 — cited; current text to be opened at leginfo.legislature.ca.gov in Batch 2. \\[WIC-TEXT\\]\n\n**California history and reporting**\n\n- [Dan Morain, \"The forgotten report that upended mental health care in California,\" Capitol Weekly / Center for Health Journalism](https://capitolweekly.net/the-forgotten-report-that-upended-mental-health-care/) — opened via extract; origins of the 1966 Dilemma report, Unruh's subcommittee. \\[MORAIN-DILEMMA\\]\n- [Local News Matters, state audit coverage (30 Jul 2020)](https://localnewsmatters.org/2020/07/30/state-audit-urges-improved-treatment-for-people-with-mental-illnesses/) — opened via extract; Petris on unfunded promise. \\[LNM-2020\\]\n- [Daily Beast, \"When going to the hospital is just as bad as jail\"](https://www.thedailybeast.com/when-going-to-the-hospital-is-just-as-bad-as-jail/) — opened via extract; DRC v. Alameda County allegations. \\[DB-ALAMEDA\\]\n- [Billboard, Britney Spears conservatorship timeline](https://www.billboard.com/pro/britney-spears-conservatorship-timeline/) and [KQED Forum, 2021](https://www.kqed.org/forum/2010101884144/britney-spears-offers-disturbing-testimony-about-conservatorship-that-she-seeks-to-be-free-from) — opened via extract; [Rolling Stone on Jamie Spears' response](https://www.rollingstone.com/music/music-news/britney-spears-conservatorship-jamie-spears-inquiry-1191429/). \\[SPEARS-2021\\]\n- [White House Plumbers (Wikipedia, with Hougan and Krogh citations)](https://en.wikipedia.org/wiki/White_House_Plumbers); [Michigan Daily, 18 May 1976 (AP) on affirmance of Ehrlichman conviction](https://digital.bentley.umich.edu/midaily/mdp.39015071754647/118/download_text); [HNN on Krogh's NYT op-ed](https://www.historynewsnetwork.org/article/40435) — opened via extract. \\[ELLSBERG-FIELDING\\]\n\n**US federal and other-state sources**\n\n- [O'Connor v. Donaldson, 422 U.S. 563 (1975)](https://supreme.justia.com/cases/federal/us/422/563/); [Addington v. Texas, 441 U.S. 418 (1979)](https://supreme.justia.com/cases/federal/us/441/418/) — standard links, not opened this batch. Vitek v. Jones, 445 U.S. 480 (1980); Zinermon v. Burch, 494 U.S. 113 (1990); Lessard v. Schmidt, 349 F. Supp. 1078 (E.D. Wis. 1972) — cited. \\[SCOTUS-COMMITMENT\\]\n- [Federal Times / MSPB, \"Whistleblowers must watch for retaliatory fitness-for-duty exams\" (2014)](https://mspb.federaltimes.com/2014/07/28/whistleblowers-must-watch-for-retaliatory-fitness-for-duty-exams/) — opened via extract; 1978 subcommittee quotation; 1.6%→6.1% survey figures. \\[MSPB-FFD\\]\n- [Whistleblower Network News, Donald Ray Soeken profile](https://whistleblowersblog.org/whistleblower-of-the-week/donald-ray-soeken/); [Government Accountability Project obituary (26 Nov 2025)](https://whistleblower.org/press/mourning-the-loss-of-whistleblower-dr-don-soeken/) — opened via extract. The 1978 House subcommittee report itself is a LEAD to locate. \\[SOEKEN\\]\n- [HRW, \"Booted\" press release (19 May 2016)](https://hrw.org/news/2016/05/19/us-raped-military-then-punished); [Task & Purpose summary with DoD IG figure](https://taskandpurpose.com/news/soldier-stood-sexual-harassment-kicked-army/) — opened via extract. DoD IG report DODIG-2016-088 — cited. \\[HRW-BOOTED\\]\n- [NYPD Confidential, Levitt columns on Schoolcraft (2010, 2012, 2013)](https://nypdconfidential.com/columns/2010/100920.html) — opened via extract; hospital-record quotations and DA draft report. \\[SCHOOLCRAFT\\]\n- [Rutherford Institute, Raub release (2012)](https://www.rutherford.org/publications_resources/on_the_front_lines/victory_circuit_court_orders_brandon_raub_released_dismisses_case_against_m); [ABC News, 2012](https://abcnews.go.com/blogs/politics/2012/08/former-marine-detained-after-alleged-facebook-threats/) — opened via extract; note the advocacy source's framing. \\[RAUB\\]\n\n**Chilling-effect research**\n\n- Swartz, Swanson & Hannon, \"Does fear of coercion keep people away from mental health treatment?\" Behavioral Sciences & the Law 21:459 (2003) — [Duke abstract](https://scholars.duke.edu/publication/691940) opened via extract. \\[SWARTZ-2003\\]\n- Blanchard, \"Concealment of Suicidal Ideation in Psychotherapy,\" Columbia dissertation — [abstract](https://academiccommons.columbia.edu/doi/10.7916/D8G73S5P) opened via extract; 107 concealers, hospitalization fear chief reason. \\[BLANCHARD\\]\n- Jones et al., \"Investigating the impact of involuntary psychiatric hospitalization on youth and young adult trust and help-seeking,\" [PMC10105343](https://pmc.ncbi.nlm.nih.gov/articles/PMC10105343/) — opened via extract; 40 interviews, selective non-disclosure after involuntary hospitalization. \\[JONES-YOUTH\\]\n- Shea et al., \"Racial and Ethnic Inequities in Inpatient Psychiatric Civil Commitment,\" Psychiatric Services (2022) — [abstract](https://psychiatryonline.org/doi/abs/10.1176/appi.ps.202100342) opened via extract; Massachusetts, aOR 1.57 for Black patients. \\[SHEA-2022\\]\n\n**International**\n\n- [van Voren, \"Political Abuse of Psychiatry—An Historical Overview,\" Schizophrenia Bulletin (2010)](https://pmc.ncbi.nlm.nih.gov/articles/PMC2800147) — opened via extract. \\[VANVOREN-2010\\]\n- [HRW and Geneva Initiative, *Dangerous Minds* (2002), ch. 2](https://www.hrw.org/reports/2002/china02/china0802-02.htm) — opened via extract; Soviet history and Chinese Ankang system. \\[HRW-2002\\]\n- [HRW, China Mental Health Law statement (3 May 2013)](https://www.hrw.org/news/2013/05/03/china-end-arbitrary-detention-mental-health-institutions); [Dui Hua, Ankang regulations vs. Mental Health Law (2012)](https://duihua.org/?p=18355); [CHRD via Amnesty UK (2013)](https://www.amnesty.org.uk/knowledge-hub/all-resources/chrb-six-months-after-mental-health-law-took-effect-involuntary-psychiatric/) — opened via extract. \\[CHINA-MHL\\]\n- [Safeguard Defenders, *Drugged and Detained* executive summary (2022)](https://safeguarddefenders.com/sites/default/files/pdf/EXECUTIVE%20SUMMARY%20EN.pdf); [RFA on Wang Wanxing and Zhong Yafang (2011)](https://www.rfa.org/english/news/china/mental-12282011101351.html) — opened via extract. \\[CHINA-NGO\\]\n- [Psychiatric News, \"Soviets Left WPA Under Expulsion Threat\" (2010)](https://psychiatryonline.org/doi/10.1176/pn.45.22.psychnews_45_22_024); [Psychiatric News, 2016 retrospective](https://psychnews.psychiatryonline.org/doi/10.1176/appi.pn.2016.10b9); [RCPsych Bulletin, \"Athens and beyond\" (1990)](https://pb.rcpsych.org/content/14/3/129.full-text.pdf+html) — opened via extract. \\[WPA-SOVIET\\]\n- Bloch & Reddaway, *Russia's Political Hospitals* (1977) / *Psychiatric Terror* (1984); Bukovsky & Gluzman, *A Manual on Psychiatry for Dissidents* (1975); Munro, \"Judicial Psychiatry in China and Its Political Abuses,\" Columbia Journal of Asian Law 14:1 (2000) — cited. \\[SOVIET-CHINA-BOOKS\\]\n\n**Histories and scholarship (cited, to be opened)**\n\n- Metzl, *The Protest Psychosis* (Beacon, 2009); Bromberg & Simon, \"The 'Protest' Psychosis,\" Archives of General Psychiatry 19:155 (1968). \\[METZL\\]\n- Cartwright, \"Report on the Diseases and Physical Peculiarities of the Negro Race,\" New Orleans Medical and Surgical Journal (1851). \\[CARTWRIGHT\\]\n- Packard, *The Prisoners' Hidden Life* (1868); Himelhoch & Shaffer, \"Elizabeth Packard: Nineteenth-Century Crusader for the Rights of Mental Patients,\" Journal of American Studies 13:343 (1979). \\[PACKARD\\]\n- Bly, *Ten Days in a Mad-House* (1887). \\[BLY\\]\n- Rosenhan, \"On Being Sane in Insane Places,\" Science 179:250 (1973); Cahalan, *The Great Pretender* (2019). \\[ROSENHAN\\]\n- Torrey, *The Roots of Treason: Ezra Pound and the Secret of St. Elizabeths* (1984). \\[POUND\\]\n- Maher, \"Anomalous experience and delusional thinking,\" Journal of Mind and Behavior 9:1 (1988) — origin of \"Martha Mitchell effect.\" \\[MAHER-1988\\]\n- Grob, *From Asylum to Community* (1991); Torrey, *Out of the Shadows* (1997) — for deinstitutionalization context; both contested on causation. \\[GROB-TORREY\\]\n\n**Batch 2 additions (worldwide)**\n\n- [Abuse in Care Royal Commission, *Beautiful Children* news release and Lake Alice timeline](https://abuseincare.org.nz/reports/inquiry-into-the-lake-alice-child-and-adolescent-unit/executive-summary/timeline) — opened via extract; [hearing transcript 25 Jun 2021](https://www.abuseincare.org.nz/__data/assets/pdf_file/0018/28260/lake-alice-child-and-adolescent-unit-inquiry-hearing-transcript-of-proceedings-25-june-2021.pdf); [Newsroom on the stayed prosecution](https://www.newsroom.co.nz/courts-stay-ends-quest-for-justice); [PMC review article](https://pmc.ncbi.nlm.nih.gov/articles/PMC10466991/). \\[NZ-LAKE-ALICE\\]\n- Arbex, *Holocausto Brasileiro* (Geração, 2013); [Tribuna de Minas, \"Holocausto brasileiro: 50 anos sem punição\" (2011, Portuguese)](https://tribunademinas.com.br/?p=66135); [CFP note](https://site.cfp.org.br/?p=27644); [Portal Tela on the 2026 closure (Portuguese)](https://www.portaltela.com/noticias/geral/2026/05/25/hospital-psiquiatrico-que-inspirou-holocausto-brasileiro-e-desativado/). \\[BR-BARBACENA\\]\n- [Meduza, news 25 Dec 2023 (Russian)](https://meduza.io/news/2023/12/25/sud-v-peterburge-napravil-viktoriyu-petrovu-na-prinuditelnoe-lechenie-v-psihiatricheskiy-statsionar-ee-obvinyali-v-feykah-ob-armii-iz-za-posta-o-shizofrenii-putina) and [explainer cards](https://meduza.io/cards/za-poslednee-vremya-figurantov-srazu-neskolkih-politicheskih-del-podvergli-karatelnoy-psihiatrii-iz-za-chego-obvinyaemogo-mogut-napravit-na-prinuditelnoe-lechenie); [Novaya Gazeta Europe, \"Особо буйные\" (16 Aug 2023, Russian)](https://novayagazeta.eu/articles/2023/08/16/osobo-buinye); [Moscow Times (Russian)](https://ru.themoscowtimes.com/2023/12/25/obvinyaemuyu-v-voennih-feikah-zhitelnitsu-peterburga-otpravili-na-prinuditelnoe-lechenie-v-psihbolnitsu-a117101); [Amnesty Urgent Action on Gabyshev (Oct 2021, Russian)](https://eurasia.amnesty.org/wp-content/uploads/2021/10/shaman-podvergnut-karatelnoj-psihiatrii.pdf); [Echo FM analysis (31 Oct 2023, Russian)](https://echofm.online/statya-dnya/vot-tak-v-rossii-stali-chashhe-primenyat-karatelnuyu-psihiatriyu). \\[RU-2023\\]\n- [UK government, Ethnicity facts and figures: detentions under the MHA](https://www.ethnicity-facts-figures.service.gov.uk/health/mental-health/detentions-under-the-mental-health-act/latest/); [Mental Health Bill 2025 fact sheet](https://www.gov.uk/government/publications/mental-health-bill-2025-fact-sheet/mental-health-bill-2025-fact-sheet); [Parliament deposited paper DEP2025-0227](https://data.parliament.uk/DepositedPapers/Files/DEP2025-0227/Evidence_summary_drivers_of_racial_disparities-Mental_Health_Act.pdf); [RCPsych, Jan 2024](https://www.rcpsych.ac.uk/news-and-features/latest-news/detail/2024/01/25/it-s-time-to-tackle-the-trap-of-inequality-and-mental-illness). \\[UK-MHA\\]\n- [Florida DCF / USF Baker Act Reporting Center, FY2015/16 annual report](https://myflfamilies.com/document/21586); [WPTV on FY2020/21 child exams](https://www.wptv.com/news/local-news/investigations/baker-act-exams-among-florida-children-reach-historic-new-high); [WUSF data page](https://www.wusf.org/health-news-florida/2020-12-15/about-the-data-committed-children-and-the-baker-act). \\[FL-BAKER\\]\n- [Canadian Encyclopedia, Duplessis Orphans](https://thecanadianencyclopedia.ca/en/article/duplessis-orphans); [historyofrights.ca](https://historyofrights.ca/encyclopaedia/main-events/duplessis-orphans/); [CBC, 1999](https://www.cbc.ca/news/canada/quebec-ombudsman-says-duplessis-orphans-right-1.173120); [Globe and Mail](https://www.theglobeandmail.com/news/national/duplessis-orphans-march-for-apology-compensation/article1039029). \\[QC-DUPLESSIS\\]\n- Cited, to open in Batch 3: Süß, *Politisch mißbraucht? Psychiatrie und Staatssicherheit in der DDR* (1998); Vinyes, *Irredentas* (2002) and Bandrés & Llavona on Vallejo-Nágera; Brown & Lago (1991); Slattery Royal Commission into Deep Sleep Therapy (NSW, 1990); WHO, *Apartheid and Mental Health Care* (1977); Korean Constitutional Court decision 2014Hun-Ka9 (2016).\n\n**Batch 3 additions**\n\n- [Hedman, Petrila, Fisher, Swanson, Dingman & Burris, \"State Laws on Emergency Holds for Mental Health Stabilization,\" Psychiatric Services 67:529 (2016)](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.201500205); updated data set at LawAtlas; [\"Reasonable or Random: 72-Hour Limits to Psychiatric Holds,\" Psychiatric Services (2021)](https://ps.psychiatryonline.org/doi/10.1176/appi.ps.202000284). \\[US-HOLD-LAWS\\]\n- [Denhof v. City of Grand Rapids, 494 F.3d 534 (6th Cir. 2007), FindLaw](https://caselaw.findlaw.com/court/us-6th-circuit/1379192.html); [Daily Record on Blake v. Baltimore County (4th Cir. 2011)](https://origintdrdev.wpengine.com/2011/07/17/4th-circuit-affirms-225000-jury-verdict-awarded-to-police-officer); [AELE police-psychology case digest (2004)](https://aele.org/psych2004.php); [Insurance Journal, Springfield OR (2021)](https://amp.insurancejournal.com/news/west/2021/03/02/603368.htm); [ABC 17, Ashland MO (2025)](https://abc17news.com/?p=1621197); [Hoodline, Duluth MN (2026)](https://hoodline.com/2026/03/duluth-cop-says-city-put-him-on-ice-for-blowing-the-whistle/). \\[US-FFD-CASES\\]\n- [Medigate News, 29 Sep 2016 (Korean)](https://medigatenews.com/news/2286485391); [PSPD Judicial Watch commentary (Korean)](https://peoplepower21.org/judiciary/1452956); [Ministry of Health and Welfare explanation, May 2016 (Korean)](https://www.incheon.go.kr/welfare/WE010221/1933931); [Jeju National University thesis with 2016 admission counts (Korean)](https://mslib.jejunu.ac.kr/bitstream/2020.oak/6060/2/%eb%b3%b4%ed%98%b8%ec%9d%98%eb%ac%b4%ec%9e%90%ec%97%90%20%ec%9d%98%ed%95%9c%20%ec%9e%85%ec%9b%90%ec%97%90%ec%84%9c%20%ea%b0%80%ec%a1%b1%ec%9d%98%20%ec%9c%84%ec%b9%98.pdf). \\[KR-2016\\]\n- [MHLW, history of mental health law revisions (2009, Japanese)](https://www.mhlw.go.jp/shingi/2009/07/dl/s0730-11b_0001.pdf); [Cabinet Office disability reform paper (Japanese)](https://www8.cao.go.jp/shougai/suishin/kaikaku/s_kaigi/k_16/pdf/s2.pdf); [Kirihara, Ritsumeikan, on the Utsunomiya incident's place in policy history (Japanese)](https://ritsumei.repo.nii.ac.jp/record/5639/files/ec11_05_47kirihara.pdf); [ben54.jp on Takiyama Hospital (2024, Japanese)](https://www.ben54.jp/news/2100). \\[JP-LAW\\]\n- [Junta de Andalucía, Antigua Cárcel de Mujeres de Málaga (Spanish)](https://www.juntadeandalucia.es/organismos/culturaydeporte/areas/cultura/memoria-democratica/lugares-memoria-democratica/paginas/antigua-carcel-mujeres.html); [Público, \"Franco, en busca del 'gen rojo'\" (Spanish)](https://www.publico.es/politica/franco-busca-gen-rojo-inferioridad.amp.html); [Mininni, eHumanista/IVITRA 23 (Spanish)](https://ehumanista.ucsb.edu/sites/default/files/sitefiles/ivitra/volume23/1.3.%20Mininni.pdf); [El Salto (Spanish)](https://www.elsaltodiario.com/memoria-historica/combatientes-contra-el-gen-rojo-o-el-fanatismo-de-los-psiquiatras-franquistas); Pérez Sales, bibliographic study (Spanish, PDF). \\[ES-FRANCO\\]\n- [Bundesarchiv, Süß, *Politisch mißbraucht?* (1998), publication page (German)](https://www.bundesarchiv.de/publikationen/publikation/politisch-missbraucht); [Zeitschrift des Forschungsverbundes SED-Staat, critique (German)](https://www.zeitschrift-fsed.fu-berlin.de/index.php/zfsed/article/download/306/290/588); [Ärzteblatt, \"Die Waldheim-Story\" and Süß's reply (German)](https://www.aerzteblatt.de/archiv/67363/Die-waldheim-story-Psychiatriemissbrauch-selbst-erlebt); [Thieme, forensic psychiatry in the GDR (2025, German)](https://www.thieme-connect.com/products/ejournals/pdf/10.1055/a-2643-5711.pdf). \\[DDR\\]\n- [FIDH / Civic Solidarity Platform, \"Political abuse of psychiatry in post-Soviet countries\" (April 2017)](https://civicsolidarity.org/wp-content/uploads/2017/05/pol-abuse-eng-april-2017-full.pdf). \\[POST-SOVIET-2017\\]\n- [Center for Human Rights in Iran, 4 Nov 2024](https://iranhumanrights.org/2024/11/student-who-undressed-to-protest-irans-repressive-dress-code-joins-other-dissidents-forced-into-psychiatric-centers/); [Iran International, older site](https://old.iranintl.com/en/iran/more-political-prisoners-being-moved-psychiatric-hospitals); [Protothema on Amnesty's evidence](https://en.protothema.gr/?p=456626). \\[IR-PSYCH\\]\n\n**Batch 4 additions**\n\n- [Radio Romania International, \"Political Psychiatry in Communist Romania\"](https://rri.ro/en/features-and-reports/the-history-show/political-psychiatry-in-communist-romania-id128387.html); [Hotnews, Ursu on Ion Vianu (Romanian)](https://hotnews.ro/opinie-de-andrei-ursu-o-misiune-de-constiinta-lasata-de-ion-vianu-1527783); [Evenimentul Zilei on Decree 313/1980 and Paraschiv (Romanian)](https://evz.ro/securitatea-lui-ceausescu-il-obliga-pe-vasile-paraschiv-sa-ia-un-tratament-care-sa-l-transforme-in-nebun-adevarat.html); [Cotidianul obituary (Romanian)](https://www.cotidianul.ro/disidentul-anti-comunist-vasile-paraschiv-a-murit/); [Reagan Library, Dobriansky files, Romania cables](https://www.reaganlibrary.gov/sites/default/files/2025-02/40-145-39146857-R05-021-2024_1.pdf); [UK National Archives file description via History Commons](https://history-commons.net/artifacts/2373816/romania/3394801/); Amnesty UK on Poiana Mare (2004). \\[RO-PSYCH\\]\n- Brown & Lago, *The Politics of Psychiatry in Revolutionary Cuba* (Freedom House / Of Human Rights, 1991); [JAAPL review (1992)](https://jaapl.org/content/20/2/237); [Seattle Times, 6 May 1992](https://archive.seattletimes.com/archive/19920506/1490272/electroshock-torture-in-cuba-alleged----ex-political-prisoners-say-they-were-subjected-to-it); [Cubanet on the Mederos conviction (2002)](https://www.cubanet.org/htdocs/CNews/y02/ago02/09e6.htm). \\[CU-PSYCH\\]\n- Report of the Royal Commission into Deep Sleep Therapy (NSW, 1990), 12 vols; [NSW State Archives description](https://researchdata.edu.au/agy-6764-royal-royal-commission/2754627); [Dictionary of Sydney entries](https://dictionaryofsydney.org/index.php/node/66876); Bromberger & Fife-Yeomans, *Deep Sleep* (1991). \\[AU-CHELMSFORD\\]\n- WHO, *Apartheid and Mental Health Care* (MNH/77.5, 1977); APA, \"Report of the Committee to Visit South Africa,\" Am J Psychiatry 136:1498 (1979); RCPsych Special Committee report (1983); [Anti-Apartheid Movement archive](https://aamarchives.org/archive/history/1980s/pro04-which-way-wpa/download.html); [O'Donoghue, Rhodes University MA (1989)](https://researchrepository.ru.ac.za/items/df46dab0-b3e9-46b8-81b4-8717e8c67967/full); [BJPsych International, \"Reconciliation and psychiatry in South Africa\"](https://www.cambridge.org/core/journals/bjpsych-international/article/reconciliation-and-psychiatry-in-south-africa/D61ADB45B24D13A383EB2C63F9C79914). \\[ZA-PSYCH\\]\n\n**Batch 5 additions**\n\n- [Review of Rafael & Melo, *Locura y suicidio en las cárceles de la dictadura*, UNPAZ (Spanish)](https://publicaciones.unpaz.edu.ar/OJS/index.php/debatesddhh/article/download/2208/2067); [La Marea, 2013 (Spanish)](https://lamarea.com/2013/08/11/la-dictadura-argentina-utilizo-la-psiquiatria-para-esparcir-su-doctrina); [Revista Salud, Universidad del Rosario, on Hospital Esteves 1960–1970 (Spanish)](https://revistas.urosario.edu.co/index.php/revsalud/article/download/2301/2005/8166). \\[AR-PSYCH\\]\n- [Revista de Psicología, Universidad de Chile, 2024 (Spanish)](https://revistaschilenas.uchile.cl/handle/2250/247452?show=full); [Última Década (Spanish)](https://ultimadecada.uchile.cl/index.php/RDP/article/download/71967/76848/289826); [Radiszcz, Sabrovsky & Vetö, Asclepio 66(1) 2014 (Spanish)](https://doaj.org/article/92893edf2e0a425798e46e1af63fa038); [Faúndez Abarca, Redalyc (Spanish)](https://www.redalyc.org/pdf/967/96728593007.pdf). \\[CL-PSYCH\\]\n- [Polis (Universidad de Los Lagos), \"Médicos y psicólogos en las dictaduras\" (Spanish)](https://revistas.ulagos.cl/index.php/polis/article/download/751/910/659). \\[CONE-SUR\\]\n\n**Batch 6 additions**\n\n- [Stockholm Center for Freedom, Uysal case (2025)](https://stockholmcf.org/?p=71174); [Turkish Minute, Tuğba Y. (28 Feb 2017)](https://www.turkishminute.com/2017/02/28/teacher-lost-sanity-detention-remains-jail-despite-doctors-reports/); [SCF on the TİHV forensic report](https://stockholmcf.org/report-turkish-man-in-police-custody-for-7-days-loses-mental-health/); [SCF on the Talu complaint and the blocked Council of Europe report](https://stockholmcf.org/?p=69384). \\[TR-ATK\\]\n- [Supreme Court of India, *In re Death of 25 Chained Inmates v. Union of India*](https://aicb.org.in/images/advocacy/SupremeCourt/In%20Re%20Death%20Of%2025%20Chained%20Inmates%20vs%20Union%20Of%20India%20And%20Ors..PDF); [CLPR case file](https://clpr.org.in/wp-content/uploads/2024/11/67_Asylum_Deaths_v_TN.pdf); [National Herald, \"The chains have gone, but the problem persists\" (2026)](https://www.nationalheraldindia.com/national/the-chains-have-gone-but-the-problem-persists); [Scroll.in on Erwadi after 2001](https://scroll.in/article/1029561/scroll_in). \\[IN-ERWADI\\]\n- [Sheridan Rains et al., \"Variations in patterns of involuntary hospitalisation and in legal frameworks,\" Lancet Psychiatry 6(5) 2019 (UCL open access)](https://discovery-pp.ucl.ac.uk/id/eprint/10072450/1/Sheridan_1-s2.0-S2215036619300902-main.pdf); [Mendeley data set](https://data.mendeley.com/datasets/4y9tdf5xxf); [BMC Psychiatry 2007 Nordic registration study](https://bmcpsychiatry.biomedcentral.com/articles/10.1186/1471-244X-7-S1-S141); [Mijaljica, European Psychiatry (2026)](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC13444966/); [BJPsych Open, worldwide coercion comparison](https://www.cambridge.org/core/services/aop-cambridge-core/content/view/79B38E26E80C6062543ED1C9B24CB3F8/S2056472423006130a.pdf/comparison-of-coercive-practices-in-worldwide-mental-healthcare-overcoming-difficulties-resulting-from-variations-in-monitoring-strategies.pdf). \\[EU-COMPARATIVE\\]\n\n**Batch 7 addition**\n\n- [\"Goldwater v. Ginzburg,\" Am J Psychiatry 172(8):729 (2015)](https://ajp.psychiatryonline.org/doi/full/10.1176/appi.ajp.2015.14111410); [Kroll & Pouncey, \"The Ethics of APA's Goldwater Rule,\" JAAPL 44(2):226 (2016)](https://jaapl.org/content/44/2/226); Goldwater v. Ginzburg, 414 F.2d 324 (2d Cir. 1969), cert. denied 396 U.S. 1049 (1970) — opinion still to open on Casetext. \\[US-GOLDWATER\\]\n\n**Batch 8 additions**\n\n- Puerto Rico: [Ley 408-2000 (docs.pr.gov)](https://docs.pr.gov/files/ASSMCA/Leyes/LEY%20408-2000.pdf); [Senate measure PS 983-22 analysis (Spanish)](https://senado.pr.gov/document_vault/legislative_measures/3163/document/ps0983-22.pdf); [Poder Judicial specialized courtrooms](https://poderjudicial.pr/Documentos/Educo/temas-legales/salud-mental/Servicios-Especializados-atender-asuntos-salud-mental.pdf). \\[PR-408\\]\n- Belarus: UN Human Rights Council, Report on Belarus, 22 Apr 2025; OHCHR experts' statement, 24 Apr 2025 (both cited in [EUAA guidance](https://www.euaa.europa.eu/belarus-political-opposition-and-dissent/331-forced-psychiatric-treatment)); [Viasna via Pozirk](https://pozirk.online/en/news/167095); [International IDEA Democracy Tracker](https://www.idea.int/democracytracker/report/belarus/april-2025). \\[BY-PSYCH\\]\n- Kazakhstan: [HRW 2013](https://www.hrw.org/news/2013/08/15/kazakhstan-lawyer-forced-psychiatric-detention); [ICJ 2013](https://www.icj.org/wp-content/uploads/2013/09/Statement-Kazakhstan-030913.pdf); [Lawyers for Lawyers letter to the Minister of Justice, 15 Aug 2013](https://www.lawyersforlawyers.org/wp-content/uploads/L4L-Letter-Kazakhstan-Minister-of-Justice.pdf). \\[KZ-MUKHORTOVA\\]\n- Querulous paranoia: Lester, Wilson, Griffin & Mullen, BJPsych 184:352 (2004); \"In defence of complainants,\" BJPsych (2004) correspondence; Mullen & Lester, Behav Sci Law 24 (2006); Kraepelin, *Lectures on Clinical Psychiatry* (1904); ICD-10 F22.8. \\[QUERULANT\\]\n\n**Batch 9 addition**\n\n- [Musée Camille Claudel, biography: 1909–1943](https://museecamilleclaudel.fr/en/collections/camille-claudel-biography/1909-1943-period-confinement); [The Conversation (2021)](https://theconversation.edu.au/britney-spearss-conservatorship-alludes-to-an-older-story-of-controlling-women-artists-164918); Loi du 30 juin 1838 sur les aliénés (repealed by loi du 27 juin 1990) — text to open on Légifrance. \\[FR-CLAUDEL\\]\n\n**Batch 10 additions**\n\n- [Mad in America, \"Madness Network News\" (2021)](https://www.madinamerica.com/2021/01/madness-network-news/); [Chabasinski, \"The history and future of our psychiatric survivor movement\" (2012)](https://www.madinamerica.com/2012/08/the-history-and-future-of-our-psychiatric-survivor-movement); [Oskar Diethelm Library, \"Anti-Psychiatry Communications\"](https://oskardiethelm.omeka.net/exhibits/show/patient-perspectives-and--anti/-anti-psychiatry--communicatio); *The Madness Network News Reader* (1974); Andre, *Doctors of Deception* (2009). \\[CA-SURVIVOR-ARCHIVE\\]\n- [ProPublica, Kern County suicide watch (2019)](https://www.propublica.org/article/a-jail-increased-extreme-isolation-to-stop-suicides-more-people-killed-themselves); [DRC, Santa Barbara jail report coverage](https://www.disabilityrightsca.org/node/791); [Babu v. Ahern joint response quoting DOJ's 22 Apr 2021 Alameda findings](https://rbgg.com/wp-content/uploads/Babu-Joint-Response-to-April-9-2021-Order-re-Santa-Rita-Jail-COVID-19-Response-04-28-2021-1378-1.pdf); [Noozhawk on the San Luis Obispo DOJ agreement](https://www.noozhawk.com/?p=664571); [California DOJ immigration detention briefing (May 2025)](https://oag.ca.gov/system/files/media/care-comm-briefing-slides-052225.pdf); [NERA, Suffolk County suicide-watch verdict](https://www.nera.com/experience/2015/pro-bono-statistical-analysis-of-prisoner-treatment-in-a-jury-tria.html). \\[CA-JAILS\\]\n\n**Batch 11 additions**\n\n- [*Bias v. Moynihan*, 9th Cir. No. 05-16752 (28 Nov 2007)](https://cdn.ca9.uscourts.gov/datastore/opinions/2007/11/28/0516752.pdf); [*Nguyen v. Lopez*, 9th Cir. No. 15-56996 (20 Mar 2017, unpublished)](https://cdn.ca9.uscourts.gov/datastore/memoranda/2017/03/20/15-56996.pdf); [*LeFay v. Panabaker*, 9th Cir.](https://caselaw.findlaw.com/court/us-9th-circuit/1762676.html); [*Nieves v. Bartlett*, 587 U.S. \\_\\_\\_ (2019)](https://law.justia.com/cases/federal/us/587/17-1174/); [*Dahlia v. Rodriguez*, 9th Cir. en banc 2013, via Public Citizen](https://www.citizen.org/news/federal-appeals-court-reinstates-first-amendment-claim-of-whistleblower-police-officer/). \\[CA-5150-CASELAW\\]\n\n**Batch 12 additions**\n\n- [San Bernardino County DBH, Office of Patients' Rights brochure (Oct 2023)](https://www.sbcounty.gov/uploads/DBH/2023/10/Patients%27%20Rights%20Brochure.pdf); DHCS California Involuntary Detentions Data Reports, [FY 2012-13](https://www.dhcs.ca.gov/services/MH/Documents/FY12_13_InvolDetRpt_12_12_14.pdf), [FY 2014-15](https://www.dhcs.ca.gov/services/MH/Documents/FY14-15_InvoluntaryDetentionReport.pdf), [FY 2015-16](https://www.dhcs.ca.gov/Documents/CSD_YV/MHSA/IDR/FY15-16-IDR-Report.pdf), [FY 2019-20](https://www.dhcs.ca.gov/Documents/CSD_YV/MHSA/IDR/FY19-20-IDR-Report.pdf), [FY 2020-21](https://www.dhcs.ca.gov/services/MH/Documents/FY20-21-IDR.pdf), [FY 2021-22](https://www.dhcs.ca.gov/services/MH/Documents/FY21-22-IDR.pdf). \\[CA-COPR\\] \\[DHCS-IDR-SERIES\\]\n\n**Batch 13 additions**\n\n- [*In re MH2023-004502*, 258 Ariz. (2025)](https://case-law.vlex.com/vid/re-mh2023-004502-1105632857); [*In re MH 2006-002044*, 170 P.3d 280 (App. 2007)](https://syfert.com/caselaw/case.php?id=6603957); [*In re MH 2009-002120* (App. 2010), summary](https://www.omlaw.com/azapp-blog/postings/2010/involuntarily-committed-mental-health-patients-due-process-rights-are-not-violated-when-a-required/); [*In re MH 2008-000438* (App.)](https://case-law.vlex.com/vid/in-re-mh-2008-890298395); Arizona session laws [2024 ch. 152 (HB 2744)](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf) and [2025 ch. 211 (HB 2742)](https://www.azleg.gov/legtext/57leg/1R/laws/0211.pdf). \\[AZ-TITLE-36\\]\n\n**Batch 14 additions**\n\n- [ASH Independent Oversight Committee, Annual Report 2020](https://ioc.az.gov/sites/default/files/2024-09/2020%20ASH%20IOC%20Annual%20Report.pdf); [Annual Report 2022-23](https://ioc.az.gov/sites/default/files/2024-10/DHS%20ASH%20IOC%20Annual%20Report%202022-23.pdf); [IOC public meeting minutes and transcript, 19 Oct 2023](https://ioc.az.gov/sites/default/files/2023-10/IOC_%20DHS_ASH%20IOC%20Meeting%20%282023-10-19%2018_03%20GMT-7%29.pdf); [Arizona Republic on withheld death reports (2023)](https://news.yahoo.com/state-health-officials-wont-disclose-130111882.html); [DRAZ access lawsuit release](https://disabilityrightsaz.org/?p=37); [FIJ on AZCIR investigation (2021)](https://fij.org/?p=13742); [Clearinghouse, CRIPA investigation of ASH (1989–95)](https://clearinghouse.net/case/432/). \\[AZ-ASH-IOC\\] \\[AZ-DRAZ\\] \\[AZ-AZCIR\\]\n\n**Batch 15 additions**\n\n- Texas Health & Safety Code ch. 573 via [HB 1738 bill analysis (2013)](https://capitol.texas.gov/tlodocs/83R/analysis/pdf/HB01738S.pdf); [SB 359 (2015)](https://www.legis.state.tx.us/tlodocs/84R/billtext/doc/SB00359S.doc); [HB 5210 (2023)](https://capitol.texas.gov/tlodocs/88R/billtext/html/HB05210I.htm); [SB 2287 (2023)](https://capitol.texas.gov/tlodocs/88R/billtext/pdf/SB02287S.pdf); [HB 5463 (2025)](https://capitol.texas.gov/tlodocs/89R/billtext/pdf/HB05463I.pdf); [Austin OPO formal complaint file](https://austintexas.gov/node/82794). \\[TX-573\\]\n\n**Batch 16 additions**\n\n- [*Richards v. Duke University*, 3d Cir. No. 05-1170 (2005, non-precedential)](https://www2.ca3.uscourts.gov/opinarch/051170np.pdf); [*James v. State of New York*, 2d Cir. (2011)](https://hallapproved.com/us/cases/ca2/2011/212975); [Maryland Court of Special Appeals, unreported No. 0037, Sept. Term 2020](https://www.courts.state.md.us/sites/default/files/unreported-opinions/0037s20.pdf); [*Powell v. Symons*, 3d Cir. (2012)](https://www.njd.uscourts.gov/sites/njd/files/Powell.pdf); [JAAPL, *United States v. Dubrule* note](https://jaapl.org/node/8997); [JAAPL, *United States v. Ruston* note](https://jaapl.org/node/4735); [Mikhail Kosenko (Wikipedia, Yaffa citations)](https://en.wikipedia.org/wiki/Mikhail_Kosenko). \\[US-RULE-17C\\] \\[RU-KOSENKO\\]\n\n**Batch 17 additions**\n\n- [JAAPL 40(2):291, \"Can a Witness Be Required to Produce Mental Health Records or to Submit to a Psychiatric Examination?\" (10th Cir. note)](https://jaapl.org/content/40/2/291); [AAPL Practice Guideline, Competence to Stand Trial](https://jaapl.org/content/35/Supplement_4/S3); [ABA Criminal Justice Standards on Mental Health (2016)](https://www.americanbar.org/content/dam/aba/publications/criminal_justice_standards/mental_health_standards_2016.authcheckdam.pdf) — standard 7-4.x: a court \"should not on its own motion order an evaluation\" except as specified. \\[US-WITNESS-IMPEACHMENT\\]\n\n**Batch 18 additions**\n\n- [Arizona 2024 ch. 152, enacted text — read in full](https://www.azleg.gov/legtext/56Leg/2R/laws/0152.pdf); [Governor Abbott, veto of SB 359 (2 Jun 2015)](https://gov.texas.gov/news/post/governor_abbott_vetoes_sb_359); [Texas LRL bill history](https://www.lrl.texas.gov/legis/billsearch/billdetails.cfm?billFileID=265810&from=advancedsearch); [USAB Jan 2006 on Mederos](https://www.justice.gov/criminal/hrsp/archives/2006/01-06USABulletin.pdf); [COPR program page](https://www.disabilityrightsca.org/what-we-do/programs/california-office-of-patients-rights-copr); [*Gonzalez v. Trevino* (2024)](https://www.supremecourt.gov/opinions/23pdf/22-1025_1a72.pdf); [W&I § 8103](https://law.justia.com/codes/california/code-wic/division-8/chapter-3/section-8103/); [*Doe v. Gallinot*, 657 F.2d 1017](https://law.justia.com/cases/federal/appellate-courts/F2/657/1017/395063/); [*Raub v. Campbell*, 4th Cir. 2015](https://www.ca4.uscourts.gov/Opinions/Published/141277.P.pdf). Cross-checked from editions 01–02: [Zaichenko (No. 2)](https://hudoc.echr.coe.int/eng?i=001-152598); [Shtukaturov](https://hudoc.echr.coe.int/?i=001-85611); [Atudorei](https://hudoc.echr.coe.int/eng?i=001-146379); [Rudenko](https://hudoc.echr.coe.int/app/conversion/pdf/?filename=001-142421.pdf&id=001-142421&library=ECHR); [X v. Finland note](https://ks.echr.coe.int/documents/d/echr-ks/clin_july_2012_eng); [Purohit and Moore](https://achpr.au.int/index.php/en/decisions-communications/purohit-and-moore-v-gambia-24101); [Ximenes Lopes](https://corteidh.or.cr/ver_ficha_tecnica.cfm?lang=en&nId_Ficha=319); [Much v. Langston order](https://law.justia.com/cases/federal/district-courts/california/cacdce/2:2016cv00863/639753/66/); [Petitt, DOL ARB Mar 2022](https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/03_2022); [Denhof 2019, 6th Cir.](https://www.opn.ca6.uscourts.gov/opinions.pdf/19a0634n-06.pdf); [Winters v. Miller 1971](https://law.justia.com/cases/federal/appellate-courts/F2/446/65/140921/); [NPS, Alice Paul](https://www.nps.gov/articles/000/alice-paul-woodrow-wilson-and-the-battles-for-liberty.htm); [NPS, Canton Asylum](https://home.nps.gov/places/canton-asylum-for-insane-indians.htm); [UN A/79/508](https://documents.un.org/api/symbol/access?l=en&s=A%2F79%2F508&t=pdf); [CAT/C/BLR/CO/5](https://docstore.ohchr.org/SelfServices/FilesHandler.ashx?enc=0Qv66OGVJGQXmN%2FnLwtrtJEZkvQ1SPL8CrX9LbeacVPtQKZYiV%2FNhkigXbLFGYfvhbrOjHEb1pbH%2F98VkFQUCQ%3D%3D); [Hake Halo testimony](https://www.abuseincare.org.nz/reports/inquiry-into-the-lake-alice-child-and-adolescent-unit/2-1-what-happened-at-lake-alice/hake-halo). \\[AUDIT-ED02\\] \\[PARALLEL-ED01\\]\n\n**Standing return point (after Batch 9).** Breadth is now complete at the regional level; the remaining work is enumerated jurisdiction by jurisdiction in the coverage index. Next pass: the 29 unsearched US states and four territories using LawAtlas plus each state's reporting body; Italy's Law 180; the Benelux statutes; Mexico and Peru; then the \"cited, to open\" items in the bibliography; then a California archival task — whether \"litigious\" or \"persistent complaints\" appears as evidence of disorder in 5150 applications or conservatorship petitions.\n\n**Batch 19 additions**\n\n- [Petitt, ARB Order of Remand, 29 Mar 2022](https://www.dol.gov/sites/dolgov/files/OALJ/PUBLIC/ARB/DECISIONS/ARB_DECISIONS/AIR/21_014_AIRP.pdf); [ARB 2022-0047](https://www.dol.gov/sites/dolgov/files/OALJ/PUBLIC/ARB/DECISIONS/ARB_DECISIONS/AIR/2022-0047-AIRP.pdf); [ARB case summaries Mar 2022](https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/03_2022) and [Sep 2022](https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/09_2022); [ALJ D&O, 21 Dec 2020](<https://www.oalj.dol.gov/DECISIONS/ALJ/AIR/2018/PETITT_KARLENE_v_DELTA_AIR_LINES_INC_2018AIR00041_(DEC_21_2020)_154529_CADEC_PD.PDF>) (unread directly); [Seattle Times on settlement](https://www.seattletimes.com/business/boeing-aerospace/delta-weaponized-mental-health-rules-against-a-pilot-she-fought-back/) (secondary). [NRC EA-96-051](https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/reactors/ea96051); [NRC/FP&L conference record](https://www.nrc.gov/docs/ML1735/ML17353A755.pdf). [Pub. L. 103-424](https://www.govinfo.gov/content/pkg/STATUTE-108/pdf/STATUTE-108-Pg4361.pdf); [Caddell, Fed. Cir. 1996](https://caselaw.findlaw.com/court/us-federal-circuit/1092287.html); [Cerulli, Fed. Cir. 2020](https://cafc.uscourts.gov/opinions-orders/19-2022.opinion.6-9-2020_1601117.pdf). [DoDI 6490.04](https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/649004p.pdf); [DoDD 7050.06](https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodd/705006p.pdf); [Air Force JAG guide to IG investigations](https://www.af.mil/Portals/1/documents/ig/jag-guide-ig-investigations.pdf). [NRC SCWE page](https://publish.nrc.gov/about-nrc/regulatory/allegations/scwe-mainpage.html); [AFRRI letter 2020](https://www.nrc.gov/docs/ML2007/ML20070K841.pdf); [CB&I letter 2013](https://www.nrc.gov/docs/ML1309/ML13092A077.pdf); [OSHA FRSA desk aid](https://www.osha.gov/sites/default/files/FRSA-Desk-Aid-FINAL-12-20-2019.pdf). [Fahlen, Cal. 2014](https://scocal.stanford.edu/opinion/fahlen-v-sutter-central-valley-hospitals-34291); [Bichai, Cal. App. 2021](https://www4.courts.ca.gov/opinions/archive/F078658.PDF); [HCPC response to Francis review](https://hcpc-uk.org/globalassets/meetings-attachments3/council-meeting/2015/march/enc-09---hcpc-response-to-the-report-of-the-freedom-to-speak-up-review). \\[B19\\]\n\n## Discovery methods for all remaining batches\n\nFrom Batch 10 onward, every jurisdiction pass runs all ten channels below before it is marked *Researched* in the coverage index; a jurisdiction searched by keyword alone stays at *Lead*. Each register row added should name which channel surfaced it, so the parallel thread can see where coverage is thin.\n\n| # | Channel | What to query | Why it works (evidence from Batches 1–9) |\n| --- | --- | --- | --- |\n| 1 | Legal instrument, not topic | The jurisdiction's own procedure names (§ 5150, temporary detention order, *placement volontaire*, 보호입원, compulsory treatment) combined with *retaliation*, *whistleblower*, *complaint*, *testimony*, *fitness for duty* | Denhof, Blake, Goldwater, Mederos and the Waldheim rehabilitation all surfaced through case law on a different cause of action, not through \"psychiatric abuse\" |\n| 2 | Complaint channels | Ombudsman reports, patients'-rights advocate logs, medical-board discipline, bar-association interventions, inspector-general findings, truth-commission chapters, NHRC-type monitors | Lake Alice, Erwadi, Chelmsford and Mukhortova were first visible in complaint records that produced no action |\n| 3 | Survivor-movement archives | Madness Network News, Insane Liberation Front, Network Against Psychiatric Assault, MindFreedom, Geneva Initiative, Memorial, Viasna, Independent Psychiatric Association of Russia, Lake Alice and Duplessis survivor committees | Case files kept by movements predate and outlast press coverage |\n| 4 | Contrary-evidence sources | Prosecutors' declinations, DA draft reports, defence filings, Amnesty's \"no generalized practice\" findings, Süß's critics, Cahalan on Rosenhan | Rebuttals name further cases and fix the evidence grade |\n| 5 | Local-language terms | карательная психиатрия · 被精神病 / 安康医院 · psiquiatría franquista / \"gen rojo\" · 私宅監置 / 宇都宮病院事件 · 보호입원 / 헌법불합치 · Zwangseinweisung / Psychiatriemissbrauch DDR · psihiatrie politică · 強制入院 · internement abusif / loi de 1838 | Korea, Japan, Romania, Belarus and Russia 2023 were invisible in English |\n| 6 | Adjacent instruments | Jail suicide-watch placement, school threat assessment, custody and guardianship evaluations, immigration detention, military discharge codes, security-clearance psychiatric reviews, academic \"fitness to practise\" | The label travels without a hospital (HRW *Booted*, Baker Act schools, FFD exams) |\n| 7 | Structural triggers | Dates and events — elections, hearings, state holidays, protests, visits — queried with hospital-admission records and NGO case lists | GDR holiday admissions and Chinese sensitive-date confinements appear only when the date is the query |\n| 8 | Named professionals and institutions | Psychiatrists and facilities recurring in contested cases (Leeks, Bailey, Vallejo-Nágera, Snezhnevsky, Serbsky, Aminabad, Mazorra, Poiana Mare, Jamaica Hospital) traced through licensing files, obituaries, inquiries and later litigation | One contested case usually points to several more |\n| 9 | Dataset gaps | For each reporting system (DHCS, LawAtlas, NHS Digital, USF Baker Act center, Viasna lists): the fields *not* collected — referral context, initiator, repeat holds — and the counties or agencies that do not report | Non-reporting jurisdictions (32 of 58 California counties for 2023) are where the record is thinnest |\n| 10 | Key cross-check with the parallel thread | Compare dedup keys; collisions mark multiply-sourced cases, near-misses mark single-source cases needing a second account | Prevents double-counting and flags evidence grade |\n\n**Batch workflow from here.** For each jurisdiction: (a) statute and procedure names → channel 1; (b) oversight bodies → channel 2; (c) movement archives and NGO case lists → channel 3; (d) local-language pass → channel 5; (e) adjacent instruments → channel 6; (f) for any case found, run channels 4, 7 and 8; (g) record the data-collection gaps → channel 9; (h) reconcile keys → channel 10. Only then update the coverage index.\n\n**What Batches 10–15 taught about discovery itself (revised ordering from Batch 16).** The first run of the method produced six corrections to the method:\n\n1. *Rebuttals first.* The strongest findings arrived through the defending side — an officer's winning testimony (*Nguyen*), a committee explaining why it could not investigate (Arizona IOC), a defence statistician's summary (Suffolk). Channel 4 now opens every jurisdiction: query declinations, dismissals, \"no evidence found,\" \"unsubstantiated,\" and \"not reached\" before querying allegations.\n2. *Psychiatry is a trailing term.* Every adjudicated US instance was won under another label — Fourteenth Amendment, sex discrimination, ADA, whistleblower retaliation. The adjacent instrument (channel 6) is searched with the legal label that would be pleaded, and \"psychiatric\" is added last to filter, never first to find.\n3. *The missing field is the target.* California cannot record a hold wrongly begun; Arizona withholds death reports; Texas writes the initiating facts on a form no one aggregates. Channel 9 moves from closing step to opening question: name the field the system does not collect, then identify which document holds it and which office can be asked for it.\n4. *Session laws over case law.* Statutes have shown intent that courts never reach: Arizona 2024 removed the clinical gate; Texas 2015 removed the firearm trace. Each jurisdiction's bill analyses and session laws are read with one question — what was made harder to see — before any case search.\n5. *Minutes over reports.* The Arizona annual report says \"retaliation concerns\"; the meeting transcript says most grievances end unsubstantiated or in retaliation. Channel 2 now reaches past published reports to transcripts, public-comment logs, board minutes and audio.\n6. *Reverse the sequence.* The complaint-to-hold pattern (Mukhortova, *Bias*, the Austin file) is visible only when the complaint is already known. Channel 1 is therefore run in reverse as well: begin from a jurisdiction's known litigants, grievance filers, whistleblowers and recall or ballot campaigners, then check whether a hold, exam or evaluation followed within a year.\n\n7) *Version is a field (Batch 18).* Two design findings (Arizona 2024, Texas 2015) rested on bill text that was never enacted. Every statute row records session, bill number, version, final action, effective date and codified section at the event date; a bill-text URL alone proves nothing. The parallel thread's twelve-field episode template is adopted for every new row.\n\n## Open questions, unverified leads, and return point\n\n**Coverage gaps in Batch 1 (explicitly not covered yet)**\n\n- California 1850s–1966: Stockton State Hospital (1853), the 1897 commitment statute, the 1909 sterilization law and its \\~20,000 sterilizations, and any pre-LPS cases of commitment used against complainants or spouses. No California-specific pre-LPS incident is in the register yet.\n- California 1970s–1990s: deinstitutionalization politics, the Reagan-era hospital closures, and whether any legislative hearing addressed retaliatory or pretextual holds.\n- California institutional contexts: jails and prisons (suicide-watch placement as discipline; Coleman litigation), K-12 and university threat-assessment holds, hospital staff whistleblowers, and police welfare checks following complaints against officers. No verified California incident in any of these yet.\n- Domestic, custody, inheritance, and elder-dependent contexts in California: probate conservatorship abuse findings (post-Spears AB 1194), Adult Protective Services records, and family-law cases where a psychiatric allegation was weighed. Only the Spears allegations are registered.\n- Sex, race, disability, sexuality, poverty: California-specific disparity data (the 2016 CSUSB emergency-department poster is a LEAD; the Alameda County suit is pending); the 1973 removal of homosexuality from DSM-II and California commitment practice before it; disability-rights litigation under the ADA and Olmstead in California.\n- Survivor and consumer movements: the Insane Liberation Front (Portland, 1970), Network Against Psychiatric Assault (San Francisco, 1972), Madness Network News (Berkeley), the Berkeley 1982 electroshock ban (Measure T) and its overturning — all California-linked and all unregistered.\n- Grave-disability holds: no state data; Auditor's DOJ data exclude them entirely.\n\n**Leads needing verification before onward use**\n\n- [ ] Martha Mitchell: contemporaneous UPI/press accounts of the June 1972 Newport Beach restraint; Steve King's later statements; confirm no 5150 was invoked.\n- [ ] Raub v. Campbell (4th Cir. 2015?): outcome of the civil suit.\n- [ ] Disability Rights California v. Alameda County / John George: docket, status, settlement.\n- [ ] Schoolcraft settlement amount: $600,000 (Wikipedia) vs. \\~$1.1 million (NY Daily News) — obtain the stipulation.\n- [ ] 1978 House Post Office and Civil Service subcommittee report on fitness-for-duty exams: full citation and text.\n- [ ] DHCS FY2017-18 table: confirm which statewide columns are child and adult 72-hour admissions.\n- [ ] Doe v. Gallinot: underlying facts of the plaintiff's detention.\n- [ ] Conservatorship of John L. (2010) 48 Cal.4th 131 and any narrowing of Roulet.\n- [ ] Russia (Arap 2007; Kosenko 2013–14) and Uzbekistan (Urlaeva) episode dates from primary reporting.\n- [ ] SB 43 (2023) and Welf. & Inst. Code §§ 5150, 5278, 8103 current text at leginfo.\n- [ ] CARE Court (SB 1338, 2022) and SB 1045 (2018) housing conservatorship: whether either carries retaliation-relevant safeguards.\n\n**Questions the evidence has not answered**\n\n1. Is there any California court or agency finding, in any era, that a § 5150 hold was imposed to retaliate or silence? None located in Batch 1.\n2. How often do certification review and Riese hearings result in release or refusal upheld? No published California rate found yet.\n3. Does any California data set record the referral context of a hold (complaint, dispute, whistleblowing)? Not in the DHCS or DOJ elements reviewed.\n4. What is the actual frequency of threatened holds (\"I'll have you 5150'd\") in domestic, workplace, or police encounters? Only anecdotal; no study located.\n\n**Return point for Batch 2.** Begin with California's pre-LPS record (1850–1966) and the 1970s–1990s legislative hearings, then the institutional contexts above, opening every \"cited\" statute and opinion in the bibliography. Keep using the dedup keys; the parallel thread should report any key collision before merging rows.\n\n**Return point for Batch 3 (worldwide mission).** Three tracks in parallel: (1) US states not yet searched, working alphabetically from Arizona, plus the five territories, using each state's emergency-hold statute and any state-level audit or reporting center as the entry point (Florida's USF center is the model); (2) Europe east and Central Asia leads — open Süß on East Germany, Amnesty's Romania reports, and HRW on Uzbekistan and Turkmenistan; (3) local-language passes for Spain (psiquiatría franquista, Vallejo-Nágera), Japan (私宅監置, 宇都宮病院事件), Korea (정신보건법 제24조 헌법불합치), Iran, Turkey and Latin America (Argentina, Chile). Every row added must carry a dedup key and state the structural difference from California in its own words.\n\n**Return point for Batch 4.** Continue the US state sweep alphabetically from Arizona using each state's hold statute and reporting body, and pull the LawAtlas data set into a per-state table (duration, initiator, judicial review, counsel). Open the Goldwater libel opinion and the 1956 Alaska debate record. Resolve the two AELE leads (Illinois mayoral-exam case; $325,000 federal jury) by case name. Worldwide: Romania (Amnesty 1980s; Paraschiv), Cuba (Brown & Lago), Argentina and Chile (dictatorship-era psychiatric records and truth-commission references), Australia (Slattery Royal Commission; Indigenous detention data), South Africa (WHO 1977; Life Esidimeni 2016–18), Turkey, India (Erwadi; 2017 Act), and the Nordic and Benelux countries. Add survivor-account sources per jurisdiction where they exist (Lake Alice and Duplessis survivors are already on record; Russia's Petrova and Iran's Sanjari accounts are via counsel or the person).\n\n**Return point for Batch 5.** Remaining from the Batch 4 list: Argentina and Chile (truth-commission references to psychiatric confinement; Hospital Borda), Turkey, India (Erwadi 2001; 2017 Act; colonial asylums), the Nordic and Benelux countries, and the US state sweep from Arizona. Verify the South African 1976 publication restriction against the statute. Open the Tismăneanu Commission chapter on psychiatry and the CNSAS Paraschiv file references. For Cuba, locate the Mederos indictment and verdict record (S.D. Fla., 2002). For survivor accounts, add Paraschiv's memoirs, Vianu's writings, and the Chelmsford patient testimonies in the Royal Commission transcripts.\n\n**Return point for Batch 6.** Open Turkey (post-2016 forensic referrals of detainees), India (Erwadi 2001; Mental Healthcare Act 2017; colonial asylum records), the Nordic and Benelux states (high involuntary-admission rates with strong procedural rights — a useful control group), Mexico and Peru, and SERPAJ's *Uruguay Nunca Más* for the Britos lead. Resume the US state sweep at Arizona and build the per-state LawAtlas table. All register conventions and dedup keys continue unchanged.\n\n**Return point for Batch 7.** The worldwide map now has rows in every region. Remaining work is depth, not breadth: (1) the US state-by-state table from LawAtlas, beginning at Arizona, with each state's reporting body and any retaliation case law; (2) the five US territories; (3) the Benelux states individually, Mexico, Peru and the rest of Latin America; (4) opening every item still marked \"cited\" or LEAD in the bibliography — the Goldwater opinion, the 1978 House subcommittee report, the Tismăneanu chapter, the Mederos verdict, the South African 1976 Act, Süß's critics in full; (5) survivor-account sourcing per jurisdiction. Dedup keys and labels continue unchanged.\n\n**Return point (after Batch 15).** California has been run through channels 1, 2, 3, 6 and 9 (Batches 10–12); still to run on California: 4, 5 (n/a), 7, 8, 10, and the Madness Network News issue-by-issue read. Arizona is Researched on the institutional side (ASH IOC retaliation pattern) and Lead on initiation. Texas is Lead after channels 1–2. Next: Texas channels 3, 6, 9; then Arkansas → Wyoming in alphabetical order, each through the full workflow; territories; Italy, Benelux, Mexico, Peru. Open leads added this session: Northern California Psychiatric Society v. City of Berkeley opinion; DOJ Alameda findings letter (22 Apr 2021); Nguyen v. Lopez district-court findings; Suffolk County suicide-watch case name; Arizona SB 1444 text; DRAZ–ASH settlement terms; enactment status of the 2023 Texas bills; Austin OPO complaint outcome.\n\n**Batch 19 — method correction 8.** Every row in the hazard-report sequence now carries a *fate of the hazard* field and an *instrument category* (A–G). A tribunal's retaliation finding is not evidence about the hazard, and a hazard later fixed is not evidence the referral was legitimate. Where the decision is silent the field reads LEAD, never \"unresolved\" by inference.\n\n**Batch 19 — unresolved leads (priority order)**\n\n1. *Petitt* remand decision and settlement record (OALJ 2018-AIR-00041, late 2022); the ALJ's exact language on publication and safety; what Delta did with the fatigue, training-record and SMS concerns; Altman's later licensing history from the state board, not press.\n2. *Diaz-Robainas*: Eleventh Circuit docket and DOL settlement order; the technical issues he raised and their NRC disposition.\n3. DoD IG and service IG semiannual reports: counts of substantiated reprisal mental-health referrals by year, and named summaries.\n4. MSPB and OSC: decisions where § 2302(a)(2)(A)(x) was the personnel action and corrective action was granted; *Caddell*'s and *Cerulli*'s disclosure content.\n5. DOL whistleblower reporter: other AIR 21, ERA, FRSA, STAA, NTSSA, OSH Act § 11(c) and ACA decisions where a psychological or fitness evaluation followed a safety report (*Estabrook v. FedEx* ALJ decision first).\n6. *Bichai*: what PACE assessed and who ordered it.\n7. State health-care whistleblower statutes and physician-health-program referrals after patient-safety reports (California § 1278.5 cases; nurse safe-harbor and reporting statutes in other states, sections to be confirmed from the codes).\n8. Survivor and union archives: ALPA and other pilot-union Section 15 / HIMS materials; nuclear employee-concerns program records; NHS whistleblower groups.\n9. Measured chilling: any study linking a psychiatric referral to a fall in reporting (none located).\n\n**Batch 19 — geographic gaps.** Located this batch: US federal (DOL, MSPB, DoD, NRC), Florida, Washington/Georgia (Delta), Louisiana, Maryland, Alaska, North Carolina, California, and England. Not yet searched for this sequence: the other US states individually; US territories; Canada (provincial health and nuclear regulators); Australia (Bundaberg and state health ombudsmen); EU member states under Directive 2019/1937; Japan (post-Fukushima nuclear workers); South Korea; Russia and post-Soviet aviation and nuclear sectors, where the earlier register already shows the instrument.\n\n\n\n**Return point after Batch 20.** (1) Open Griffin (ARB 1998) and Mandreger (Sec'y 1994) as primary decisions — the contrary rows matter as much as the findings. (2) Locate the FAA's record behind the AP's commute-time finding in *Petitt*. (3) *Saporito* remand decision and transcript. (4) DoD IG reprisal-referral counts. (5) DOL reporter sweep from *Estabrook v. FedEx*. Edition 03's Parts B–E geographic and earlier-batch material is otherwise already reflected in this record; its coverage ledger remains a work inventory, not a finding.\n","visibility":"public research edition","published_text_sha256":"19482a31680690a06af1c0aaa2a1684ec2ba7b6a90d407c701290e6faac79207"},{"id":"DOC-15b8efeaf6dfd366","title":"Batch 21 — Psychiatric labels and fitness referrals applied to safety-relevant engineers","source_sha256":"0790be42ae7ce75d8a62d863e12a7d2436498214df3954e6a1306eb2c0699abc","text":"# Batch 21 — Psychiatric labels and fitness referrals applied to safety-relevant engineers\nDate of work: 7 Oct 2026. Extends Batches 1–20. Nothing earlier is deleted. Carry-forward corrections stand (Diaz-Robainas: retaliatory evaluation order, no examination occurred; Petitt: pilot, comparison only, never counted as an engineer; Petitt settlement terms confidential; Diaz-Robainas NRC penalty paid 3 Dec 1996).\n\n\n\n## 0. What this batch did, in one paragraph\nIt went back to the engineering-specific leads, read the Diaz-Robainas primary decision in full, found and read a second engineering case not previously in the archive (Patrickson v. Entergy), and tested other leads. Result: two adjudicated engineering episodes, both US nuclear (1991, 2003). In both, the instrument was a fitness-for-duty referral, not a diagnosis. No case was found of an identified clinician diagnosing a safety-reporting engineer with a psychotic or personality disorder. That is a \"not found in what was searched\", not a statement that it never happened. Search was heavily weighted to US Labor Department records; international and local-language coverage is a gap (Section 6).\n\n## 1. Definitions used (from the brief)\nLabel types: L1 diagnosis by identified clinician; L2 employer/colleague informal label; L3 fitness-for-duty referral or demand without diagnosis; L4 hospitalization/detention; L5 label alleged by the person, not corroborated.\nInstrument categories A–G carry over from Batch 19 (A = employer fitness-for-duty or contractual evaluation).\nEvery row also carries: engineering role verified? / fate of the hazard / Griffin test (what unusual behaviour was observed before the referral).\n\n## 2. Plain-language account, chronological (what the records support)\n- By 1991: US nuclear licensees run mandatory fitness-for-duty programs (10 CFR Part 26, cited in the decisions; start date not verified here). The same programs that exist to catch impairment give managers a discretionary route to order a psychological evaluation. The Labor Secretary later said NRC mandates \"do not prevent\" an employer from abusing such a policy (paraphrase of Diaz-Robainas, 1996).\n- 1991, Florida (Turkey Point): Senior I&C engineer Regino \"Richard\" Diaz-Robainas, in dispute with managers over pressure-transmitter replacement and other projects, is ordered to a psychological fitness-for-duty evaluation on 30 July 1991. He does not attend. He is fired 19 August 1991 for refusing. The Secretary of Labor (19 Jan 1996) finds the order itself was motivated solely by retaliation. No examination ever took place.\n- 1993–1996: The doctrinal question is contested inside the Labor Department. The ALJ (29 Oct 1993) treated the order as non-punitive and not adverse. The Secretary (1996) reversed: an order to submit to evaluation can be an adverse action, and motive is the issue.\n- 2003, New York (FitzPatrick): System engineer Carl Patrickson, a self-described \"prolific reporter of problems\" who had told the NRC about a pump-room ventilation concern in 1997 and OSHA about other hazards in 2003, has a hallway confrontation with the plant's general manager and sends an all-capitals email. On 27 March 2003, eight days after OSHA signed its citation and three days after he showed those findings to HR, site management and corporate headquarters decide on a for-cause drug/alcohol test and a psychological evaluation. Drug test negative. The psychologist's report to the employer found \"no significant pathologies\" but recommended counseling and six months of intensified behavioural observation. He is out 31 days, returns 28 April on those conditions, and is fired 20 Nov 2003 after a performance plan. ALJ recommended decision 3 Mar 2005; ARB final decision 31 Aug 2007. Per the 7 Oct engineering addendum in the uploaded Complete library (not independently verified by me): the ALJ's recommendation was favourable to Patrickson, the ARB rejected the retaliation claim and reversed reinstatement, and the Second Circuit upheld the result on 18 Dec 2008. He is NOT counted as an established retaliation finding.\n- 2007: ARB adopts the \"materially adverse\" standard across the statutes it hears (Powers, 31 Aug 2007), the test later used to decide whether a referral counts.\n- 2022: Petitt (pilot) ARB decision treats a compulsory psychiatric evaluation as adverse only case by case (carried; comparison).\n\n## 3. Case cards\n\n### 3.1 Diaz-Robainas v. Florida Power & Light, 92-ERA-10 — VERIFIED (primary read in full this batch)\nPrimary: Sec'y of Labor, Decision and Remand Order, 19 Jan 1996: https://kkc.com/wp-content/uploads/2023/02/D-Rv.FPL_.pdf (scanned copy; verify pagination against the reporter). NRC EA 96-051: https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/reactors/ea96051\n1. Person/role: Regino R. Diaz-Robainas (NRC and coworkers use \"Richard\"). Engineer at Florida Power 1980–19 Aug 1991; Lead Engineer, Instrument & Control (1985); Senior Engineer when fired. Turkey Point Nuclear Plant. Engineering role VERIFIED from the decision's own findings.\n2. Concern: disputes with supervisor Bob Wade over replacing pressure transmitters that were to sense a loss-of-cooling accident, and over the Westinghouse setpoint study and ERDADS (a post-TMI operator-information system). \n3. Label: none clinical. Instrument = order to a psychological fitness-for-duty evaluation with the employer's consultant Dr. Dennis Johnson (L3). Informal characterisations in the record (L2): Hosmer saw him as \"overwhelmed and stressed out\"; Wade's appraisal called him not \"practical at times\" and unwilling to entertain others' opinions.\n4. Initiator and stated grounds: John Hosmer, Director of Nuclear Engineering. Grounds shifted: stress and declining performance, then fear of \"sabotage\". Early July 1991 the division president asked managers about employees in performance counselling who might attract \"adverse newspaper or NRC reactions\" and suggested considering fitness for duty. Hosmer acted on 26–30 July after Robainas threatened to go to the Miami Herald.\n5. Sequence: Mar 1990 drug-policy objection; Feb 1991 below-average appraisal and 23 Feb letter alleging retaliation; 30 Apr interim review; 2 May internal Speakout complaint; 30 Jul order; 2 Aug no-show, badge pulled; 9 Aug Hosmer learns of NRC contact; 19 Aug refusal and firing; complaint filed 29 Aug 1991.\n6. Independent assessment and contrary evidence: first-line supervisor Pagnozzi saw him daily and never questioned his fitness; coworkers and the ombudsman saw no instability; Dr. Johnson never met him and had only partial documents. Contrary: the Secretary accepted that the Feb and Apr performance ratings had valid reasons and were not shown pretextual, accepted Robainas had said he was under stress, and agreed Hosmer had a duty to ensure fitness. The ALJ had treated the evaluation as non-punitive.\n7. Findings: ALJ R.D.&O. 29 Oct 1993: dismissed. Secretary 19 Jan 1996: reversed on discharge; \"Hosmer's explanation is a pretext\"; order \"based solely on retaliatory animus\" (quoted by NRC from the Decision at 8). Remanded for remedy; not a final remedy decision. NRC: $100,000 civil penalty (paid 3 Dec 1996, per DD-97-20, carried). Settled before ALJ remedy ruling (carried).\n8. Consequences and hazard: fired; reinstatement and back pay ordered; settled. Fate of hazard (UPGRADED from LEAD): the Secretary records that Florida Power \"ultimately agreed\" and replaced the transmitters, and that the plant eventually agreed with him on ERDADS. The record does not show whether he was credited.\n9. Griffin test: first-line observer saw nothing; the referral decision-maker had seen him twice in 1991. Result: referral not supported by observed behaviour (Secretary's finding).\n10. Remaining uncertainty: settlement terms; whether the setpoint study concern was resolved; the ALJ's full reasoning (not read). Next source: ALJ R.D.&O. 29 Oct 1993.\nStatus: VERIFIED.\n\n### 3.2 Patrickson v. Entergy Nuclear Operations, 2003-ERA-22 — facts VERIFIED from the ALJ record; final outcome: retaliation NOT established (ARB reversed ALJ; Second Circuit affirmance per addendum, unverified by me)\nPrimary read: ALJ Recommended Decision and Order, 3 Mar 2005, pp. 1–about 31 of the file: https://www.citizen.org/wp-content/uploads/entergydiscriminationsuit.pdf. ARB final decision, ARB Nos. 05-069 and 05-070, 31 Aug 2007: NOT read (oalj.dol.gov blocks automated access); only DOL digest summaries seen: https://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007\n1. Person/role: Carl R. Patrickson, engineer, James A. FitzPatrick plant (NY Power Authority, then Entergy from Nov 2000). Maintenance engineer 1989; field engineer 1991–2000 (monitoring plant modifications); system engineering \"assistant engineer\" from May 2000, monitoring systems for proper operation and maintenance. Engineering role VERIFIED. Safety responsibility is system monitoring and problem reporting; he is not a titled safety engineer.\n2. Concern: emergency service water pump room ventilation: closed fire dampers could let pump motors overheat and fail in a fire. Reported to NRC 1997 (RI-1997-A-0126) and again 31 Mar 2003 (RI-2003-A-0053); also six OSHA-type items reported to the ethics line (Jun 2002) and OSHA (13 Jan 2003). OSHA inspected in Mar 2003.\n3. Label: L3 plus L2. For-cause drug/alcohol test and psychological evaluation via the employer's EAP vendor (EMAX). Employer's descriptors: \"aberrant behavior\", \"out of character\", \"excited emotional state\". The general manager testified: \"I wouldn't say screaming, you know, crazy\". His worst-case rationale: someone \"acting crazed\" might injure someone or tamper with the plant. No diagnosis. Clinical output (L1-adjacent, but not a diagnosis): the EMAX report found \"no significant pathologies\", recommended short-term stress counselling and at least six months' intensified behavioural observation; the report was written by the EMAX vice-president, but a local psychologist, Dr. Joel Richman, saw him.\n4. Initiator and grounds: general manager O'Grady (email 26 Mar), then a 27 Mar meeting of the HR director Zimmerman, O'Grady, engineering director Limpias and site VP Sullivan, plus a call to Entergy Nuclear Northeast in White Plains. Cited policy: AP 11.01 fitness-for-duty program, derived from 10 CFR Part 26. Sullivan said he feared Patrickson \"could do harm to himself\" or equipment, and admitted he knew of no past harm to equipment.\n5. Sequence: 1996–97 disputed evaluations and 1997 NRC report; Jun 2002 ethics-line report; 13 Jan 2003 OSHA letter report; 15 Jan and 25 Feb random tests; 19 Mar OSHA citation signed (minor fine on one item); 24 Mar he shows HR the OSHA findings; 25/26 Mar hallway encounter; 27 Mar email and for-cause referral; leave; 31 Mar second NRC report; 1–3 Apr negative drug test, evaluation, report; 22 Apr his OSHA retaliation complaint; 28 Apr return under agreement; 2003 performance plan; 20 Nov termination.\n6. Contrary and independent evidence: OSHA's regional administrator (17 Jul 2003) found referral legitimate because of \"out of the ordinary behavior\". The HR director described him as quiet and calm, which supports both \"out of character\" and \"no history of instability\". Fewer than five for-cause tests since 2000 at the plant. Patrickson testified he knew no one else kept on 31 days' leave after a negative test or put under six months' observation; Zimmerman said it was the first such programme Entergy had heard of. Patrickson told HR he \"kind of used the NRC thing as a shield\" for a year or two (Zimmerman's memo; Patrickson called \"spiteful\" too strong). O'Grady admitted knowing of the OSHA complaint but testified the ventilation issue was never brought to him; Patrickson said his 2002 \"Short List\" (which included ventilation) was emailed to O'Grady, though he admitted never discussing it with him. Unresolved conflict about who knew what.\n7. Findings: OSHA 17 Jul 2003: no violation. ALJ 3 Mar 2005: finding on the evaluation NOT read. DOL's own ARB digest says the ALJ found the performance-plan meetings were adverse action and found disparate treatment, and that the ARB reversed both and found no pretext for the discharge. That implies the discharge and plan claims were not sustained; it does not say how the evaluation referral was decided. \n8. Consequences and hazard: 31 days' paid leave, return-to-work conditions (stress counselling, six months' observation), then discharge on 20 Nov 2003. Fate of hazard: NRC wrote (28 Apr 2003) that absent new information it had no basis to revise its earlier conclusion that the problems were valid but adequately addressed. Patrickson testified permanent modifications were cancelled. ALJ record shows a 2003 mod list marking two as cancelled. NOT resolved here; no independent check of the 2003 fire analysis.\n9. Griffin test: observed behaviour = a raised-voice hallway exchange and an all-caps email, in a man others call calm. The test is met on the employer's account and contested on his. The independent clinician found nothing pathological. Neither fact settles motive.\n10. Uncertainty / next source: the ARB decision text (05_069.ERAP; try mirror or Westlaw); ALJ conclusions section; whether the evaluation was held adverse; later NRC discrimination findings under allegation RI-2003-A-0053.\nStatus: VERIFIED for facts quoted from the ALJ record. Final adjudicated outcome is against the retaliation claim; whether any reviewing body specifically ruled on the evaluation referral remains unread. The case stays in the register as a contrary/qualified row: independent clinician found no pathology, yet conditions were imposed, and reviewers did not find retaliation.\n\n## 4. Case table\n| Tier | Case | Role | Label type | Outcome (what a body found) | Hazard fate |\n|---|---|---|---|---|---|\n| Verified | Diaz-Robainas, FL, 1991–96 | Senior I&C engineer, Turkey Point | L3 order; L2 \"stressed\" | Secretary: order solely retaliatory; NRC penalty | Transmitters later replaced (Secretary) |\n| Verified facts; retaliation not established on review | Patrickson, NY, 2003–08 | System engineer, FitzPatrick | L3 + L2; psychologist: no pathology | OSHA: legitimate; ALJ recommended for him; ARB 2007 reversed, no pretext for discharge (digest); 2d Cir. 2008 affirmed (addendum, unverified) | NRC: adequately addressed; contested |\n| Supported (digest only) | Wells v. Kansas Gas & Electric, 85-ERA-22 (Sec'y 21 Mar 1991) | QA inspector, Wolf Creek (role from 10th Cir. 780 F.2d 1505; identity of the 85-ERA-22 complainant not confirmed) | evaluation ruled invalid | Secretary, as paraphrased in Diaz-Robainas: evaluation invalid when based on a background report already found to be discrimination | Unknown |\n| Lead | Saporito v. FPL, 89-ERA-7/17 | role not verified here | alleged \"sabotage\" characterisation | Sec'y 1994: refusing to disclose concerns protected; no final finding on sabotage claim | Unknown |\n| Lead | Floyd (90-ERA-39); Freels (95-CAA-2); Smith v. Esicorp (93-ERA-16); Mandreger (88-ERA-17); DeFord (1983) | unverified | various | not read | unknown |\n| Lead, adjacent role | PECO/Limerick security contractor employee, ALJ 22 Jun 1992; Secretary approved settlement 11 May 1994 | security, not engineer | psychological evaluation 1992 | NRC document cites the Diaz-Robainas ALJ ruling; see https://www.nrc.gov/docs/ML2006/ML20069K254.pdf | n/a |\n\n## 5. Analysis\nLabels (what actually appears). In the engineering-specific records the dominant label is \"fitness for duty\" (L3), accompanied by informal terms (L2): \"stress\", \"aberrant\", \"out of character\", fears of sabotage or self-harm. The words paranoid, delusional, persecution complex and personality disorder do not appear in either verified engineering record. They do appear in adjacent cases (Griffin, Petitt) and in the NTSB airman lead. I have no evidence these terms were applied to engineers; I also did not search enough to say they were not.\n\nMechanisms (carry the nine from Batch 19). Seen here: 1 credibility displacement (the order replaces argument about transmitters or fire dampers with argument about the man); 2 removal at moment of speech (Diaz-Robainas: after the press threat; Patrickson: 8 days after OSHA signed its citation); 3 procedural shadow (31-day leave, return-to-work conditions that a negative result did not end); 7 welfare/safety framing as pretext (Secretary found it so in 1996; contested in 2003). Mechanism 4 (durable record) is plausible in Patrickson, with six months' documented observation, but no document shows it was used later.\n\nWhat the two cases do not show: that the hazard was wrong. In the one case with a fate on record, the engineer's technical position was later adopted. In the other the regulator found the concern had been handled. Adjudication here decides the employment question, not the safety question.\n\nDifferences by period. The legal treatment shifts: ALJ 1993 (non-punitive, not adverse) → Secretary 1996 (can be adverse; motive decides) → ARB 2007 (materially-adverse standard) → ARB 2022 (Petitt: case by case). Practice shifts: the 1991 order was blunt (refuse and you are fired); the 2003 process was institutional (HR, corporate, EAP vendor, return-to-work agreement). That is two data points, not a trend.\n\nDifferences by industry. Only nuclear (with its mandatory fitness-for-duty regime) is documented. Aviation (Petitt), trucking (Griffin, Frausto, per digest: \"bizarre and disruptive behavior\" upheld as a legitimate ground), and rail have their own safe-harbour rules. Whether engineers outside regulated-FFD industries (civil, structural, chemical, product) experienced this is not answered: no case found; search coverage thin.\n\nDifferences by country. Not established. Only US records were substantively reached. See gaps.\n\nWhat the evidence can say about recurrence. Two adjudicated engineering episodes (1991, 2003) in one industry in one country is a floor, not a rate. Biases: only contested, adjudicated or published matters surface (Diaz-Robainas and Petitt both settled before remedies were finalised); the two cases I could read are ones where the employee kept litigating; nuclear fitness referrals are routine, so a referral alone is weak evidence of motive; engineers who accepted an evaluation quietly leave no record; databases code these as discharge, discrimination or access authorization rather than psychiatric.\nWhat would be needed to estimate frequency: (1) a census numerator: all OSHA/ALJ/ARB/DOE Part 708 files mentioning psychological, psychiatric, fitness-for-duty or EAP, coded by role; (2) a denominator: allegation counts (NRC allegation program; DOE employee-concerns offices) or headcount of reporters; (3) a comparison group: referral rate among non-reporters (NRC fitness-for-duty semiannual reports list for-cause \"behavior\" tests per plant, e.g. Waterford 3, Jul–Dec 2002: one; https://www.nrc.gov/docs/ML0306/ML030640743.pdf); (4) outcomes: how many were found retaliatory, upheld, cleared. Without a comparison group, no rate can be read as elevated.\n\n## 6. Search log (Batch 21 only)\nRepositories: DOL OALJ Nuclear and Environmental Whistleblower Digest Div. XIII (fetched; page truncated before XIII B 11 \"Referral to employee assistance program/medical or psychological evaluation\", the key section, NOT read); DOL ARB caselists (Aug 2007; ERA lists); NRC enforcement (EA 96-051; ML20069K254 snippet); NRC FFD six-month reports (snippets); DOE Office of Hearings and Appeals summaries (Parts 708 and 710; snippets only); Public Citizen-hosted ALJ decision; kkc.com and whistleblowers.org mirrors of DOL decisions; NTSB; news (Boeing); Substack (one item).\nTerms: engineer + safety + psychiatric/psychological evaluation/fitness for duty/paranoid/mentally unstable/delusional; \"Patrickson Entergy\"; \"Wells Kansas Gas\"; \"Smith v. Esicorp\"; Part 708/710 + psychologist + safety concerns; Russian: engineer + psychiatric expertise + unsafe + compulsory hospitalisation.\nLanguages: English; Russian (one query; irrelevant results; poor query design, not evidence of absence). NOT searched: Japanese, Korean, French, German, Spanish, Chinese, Ukrainian beyond incidental, UK tribunal databases, Canada, Australia.\nAccess gaps: oalj.dol.gov decision pages are robots-blocked (Patrickson ARB, Griffin, Mandreger unread); Westlaw/Lexis/ADAMS full text; DOE OHA index not queried directly; no professional-archive, union, oral-history or legislative-hearing search this batch.\nReviewed, no psychiatric element seen, not counted: von Bargen (Sandia safety engineer, TBH-0034); Trask (LANL engineer, WBU-15-0003); Hasan (various ERA civil/structural engineer cases); Tracanna (TAPS electrical inspector; constructive discharge rejected); Hoffman v. NextEra (assistant operations manager; constructive discharge rejected); McNeill v. Crane Nuclear; Boeing: Woods (disclosed his own ADD/OCD/depression at hire; no employer labelling seen), Barnett (family alleges PTSD from the work environment, which is alleged harm, not a label applied), Salehpour, Fauver.\nComparison section (not engineers, not counted): Petitt (pilot); Griffin and Frausto (drivers; behaviour grounds upheld, per digest); NTSB Order EA-5695, 2 Jan 2014 (airman; FAA flight surgeon sought psychiatric evaluation citing \"suspected paranoid ideation\" in 1970s records and \"highly improbable\" allegations in a 2012 letter; outcome unread; respondent not recorded); Indian Point security officer (S.D.N.Y., 290 F. Supp. 3d 234; for-cause evaluation after a reported hallucination; not a safety report; outcome unread). Unverified current item: a Substack account of a Pennsylvania involuntary commitment mentions whistleblower litigation and a record using \"paranoid and delusional\"; engineering role not established; single advocacy source; not counted.\n\n## 7. Next batch (22) queue\n1. Re-fetch DOL Digest Div. XIII with a much higher size limit and read XIII B 11 in full; list every case and classify by role.\n2. Get Patrickson ARB text (mirror/Westlaw) and the ALJ conclusions pages; then NRC allegation RI-2003-A-0053 follow-up.\n3. Griffin and Mandreger primaries via mirrors (kkc.com, whistleblowers.org, CourtListener); Wells 85-ERA-22; Floyd; Freels; Smith v. Esicorp; Saporito remand.\n4. DOE Part 710 channel: query OHA for engineers with a safety-report history who were sent for a DOE psychologist.\n5. NTSB EA-5695 full text (comparison).\n6. International: UK employment tribunals (protected disclosure + psychiatric/fitness), Japan, Korea (Gori, Kori), Canada (CNSC), Soviet-era sources (Podrabinek, Bloch & Reddaway, Memorial lists), in local languages with better query design.\n7. Professional and union archives (NSPE Board of Ethical Review, IEEE, ASME, IBEW, UCS, GAP); oral histories; Senate Hanford hearing (S. Hrg. 113-370) read for any psychiatric references.\n8. Frequency design: pull NRC FFD six-month reports for 3–5 plants over 10 years; cross-match against allegation data via FOIA.\nStanding rules unchanged: rebuttals first; Griffin test on every referral; missing field = opening question; version for every statute row; \"psychiatric\" is a trailing term.\n\n\n\n","visibility":"public research edition","published_text_sha256":"05c366f0d1c1492e7b125a1ee5dc1c27993c7b02996fd62561ccccc0499a8b38"},{"id":"DOC-8f03cf5e29f26c05","title":"Batch 22 — Referral consequences, contaminated background records, and appeal reconciliation","source_sha256":"58fdb086a28976f6adb1132699e2fce4bd75454ab747614052bc63c53d8f6eeb","text":"# Batch 22 — Referral consequences, contaminated background records, and appeal reconciliation\n7 October 2026. Bounded US administrative-record pass. Extends Batch 21; originals remain unchanged. This batch does not complete the international or engineering-role census.\n\n## Source standing\nDOL EDIG13 and EDIG8 were downloaded in full through ordinary public HTTP access and read at the relevant sections. These are official agency digests, not the underlying decisions. Local HTML snapshots are supplied. Browsing retrieval returned 403 for some pages while ordinary retrieval succeeded for these two digests; no authentication or access control was bypassed. Decision URLs failed with 404, timeout, or 403 as logged below.\n\n## 1. Patrickson — appeal result confirmed in official register, referral ruling still open\nKey: 2003-US-NY-PATRICKSON. DOL's 2002–2003 ERA caselist identifies ALJ 2003-ERA-22; recommended decision 3 March 2005; ARB final decision 31 August 2007; and Second Circuit No. 07-4574, 18 December 2008, petition for review denied. The official indexed register confirms the appeal result independently of the earlier addendum. Full circuit decision bytes were not retrieved in this pass. Status: VERIFIED (official register/indexed record) for procedural result; primary judgment text still outstanding. Do not promote this to primary judgment read.\nThe DOL adverse-action digest confirms the Board rejected the ALJ's treatment of performance-plan meetings and found no proven pretext. That does not independently resolve the evaluation referral. The earlier general claim that reviewers found no retaliation must not be restated as a specific finding that the psychological referral was justified.\nSources:\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/CASELISTS/ERALIST8\nhttps://www.dol.gov/agencies/oalj/PUBLIC/ARB/REFERENCES/CASELISTS/08_2007\n\n## 2. Referral section recovered — two entries, with different consequences\nThe actual XIII B 11 section contains Mandreger and Smith. It is not a complete census of psychiatric referrals: other pertinent entries appear elsewhere in the digest.\nMandreger v. Detroit Edison, 88-ERA-17, Secretary 30 March 1994: the digest distinguishes an EAP referral from its consequences. A psychologist found a mental disorder; the worker could not return to the plant, exhausted leave, and later received work with reduced overtime and advancement. Those consequences were adverse action. Engineering role and the precise diagnosis remain unverified; adverse action alone does not establish retaliation.\nSmith v. Esicorp, 93-ERA-16, Secretary 13 March 1996: a compelled doctor visit was adverse but not necessarily retaliatory. The digest reports substantial support for medical attention and a possible safety risk. The worker alleged suppression of scaffolding concerns but had been assigned responsibility for fixing the scaffolding. This is a medical-referral comparison, not evidence of a psychiatric diagnosis or an engineering role.\nSource: EDIG13, XIII B 11.\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG13\n\n## 3. Wells — incorrect background material can infect a later evaluation\nKey: 1991-US-KS-WELLS-85ERA22. Official digest SUPPORTS a finding in Wells v. Kansas Gas & Electric, 85-ERA-22, Secretary 21 March 1991. A security-clearance psychologist received inaccurate or unexplained background information already implicated in a successful whistleblower complaint, without context concerning that complaint and reinstatement. The employer used the recommendation to discharge the worker three months after reinstatement. The Secretary found the evaluation invalid in the context of the earlier reinstatement/expungement order and an ERA violation for noncompliance. The digest's editor reports the later appeal was dismissed but explicitly lacks the dismissal order.\nThis connects the 85-ERA-22 proceeding to 83-ERA-12 in the agency's account, strengthening the litigation-family link. It does not independently confirm the person's full identity or engineering qualifications. Keep it outside the engineer count pending role verification.\nSource: EDIG8, VIII B 1 d.\nhttps://www.dol.gov/agencies/oalj/PUBLIC/WHISTLEBLOWER/REFERENCES/REFERENCE_WORKS/EDIG8\n\n\n\n\n\n\n\n\n## 5. Search log and return point\nRead: full relevant sections of EDIG13 and EDIG8. Search engines supplied DOL register/caselist records. Tried underlying Patrickson ARB on oalj.dol.gov (404), dol.gov (timeout), circuit PDF (404), and Public Citizen ALJ PDF (403). A reproduced circuit opinion was found on Midpage, but it is not treated as a court-hosted retrieval or used to close the referral question.\nNext: underlying Wells and Mandreger decisions; engineering-role confirmation; Patrickson ALJ conclusions and ARB referral treatment; full circuit order; DOE Part 710 and non-US routes from Batch 21. International and local-language coverage remains incomplete.\n","visibility":"public research edition","published_text_sha256":"1459c7d7cb3c97b665b9ab9e5441410dcc9350777f7cab0a28c6e14841aa83b6"},{"id":"DOC-601bed5c63841332","title":"Detailed qualitative pattern cards","source_sha256":"6ce26ccb7c713dddd27a4d958e7cc92a80190e95fc6e16eb8b546c5fbdbe3afc","visibility":"public edited research text","text":"## The report becomes an inquiry into the reporter\n\nA substantive concern is followed by scrutiny of its author; the original concern needs its own disposition.\n\nSupporting material: Diaz-Robainas: official retaliation finding; Petitt: affirmed administrative merits finding\n\nContrary material: Griffin: referral justified on independent evidence; Mandreger: employer prevailed despite evidence of hostility\n\nWhat to look for: Code only a documented shift in decision-making subject, with separate dates and asserted reasons. A referral after speech alone does not establish retaliation.\n\nAccountable practice: Keep two linked records: the issue reported and any action concerning the reporter. Neither closes the other automatically.\n\nUnknowns: Fate of the original hazard is often missing from the employment decision. Missing in a reviewed source does not mean no investigation occurred.\n\n## Clearance does not end the demand\n\nA favorable assessment is followed by additional treatment requirements or continued restrictions.\n\nSupporting material: Meeker: two fitness clearances followed by an unlawful counseling requirement\n\nContrary material: A new independently documented safety concern can justify a new assessment; no matched positive case has yet been coded.\n\nWhat to look for: Record assessment scope, date, subsequent evidence and decision-maker. Do not treat clearance as proof that all future restrictions are improper.\n\nAccountable practice: Show the current assessment and the specific new basis for any continuing restriction; include a review date.\n\nUnknowns: Generalization currently rests on one anchor episode. Need independently justified repeat-assessment comparisons.\n\n## A disputed record travels\n\nAn adverse account reaches another authority or context before review or correction is complete.\n\nSupporting material: Petitt: regulator communication described in the source record\n\nContrary material: Required safety reporting may legitimately precede a final employment decision; verify governing duties at the event date.\n\nWhat to look for: Code actual transmission, recipient, purpose, authority and the decision state at transmission. Do not infer disclosure from the mere existence of a record.\n\nAccountable practice: Preserve source status and correction history when information is shared; support correction to authorized prior recipients.\n\nUnknowns: Cross-system correction delivery is not demonstrated by changing the originating record.\n\n## The complaint route depends on the subject of the complaint\n\nA route for redress depends on records or access controlled by the institution being challenged.\n\nSupporting material: Arizona IOC reports: recorded retaliation concerns and limits on investigation\n\nContrary material: A complaint body may be independent yet lack a particular remedy. Absence of release power is not absence of an intake route.\n\nWhat to look for: Distinguish patient-reported fears, oversight observations and adjudicated retaliation. Identify control over records, access, investigation and remedy separately.\n\nAccountable practice: Make the recipient, available powers, conflicts, escalation options and disposition visible.\n\nUnknowns: No prevalence estimate or proof that all grievances result in retaliation.\n\n## A favorable decision arrives before practical repair\n\nA ruling or clearance is followed by unresolved compensation, reinstatement, costs or correction.\n\nSupporting material: Denhof: later recertification-cost litigation; Petitt: merits/back pay affirmed, other awards vacated and settlement followed\n\nContrary material: A timely implemented remedy is a needed comparison; it is not supplied by settlement status alone.\n\nWhat to look for: Track merits decision, remedy order, delivery and remaining harm separately. Delay alone does not prove intentional obstruction.\n\nAccountable practice: Do not mark an issue repaired when an order merely exists. Record each remedy and evidence of delivery.\n\nUnknowns: Settlement confidentiality limits what can be said about actual compensation or terms.\n\n## Resolution is offered with a restriction on speaking\n\nA proposed agreement connects relief with limits on protected reporting or participation.\n\nSupporting material: Delcore: restrictive settlement proposal held unlawful\n\nContrary material: Some confidentiality obligations are lawful; jurisdiction, wording, scope and exceptions matter.\n\nWhat to look for: Code proposed versus signed versus enforced terms separately. No psychiatric intervention is established in Delcore.\n\nAccountable practice: Keep the relief sought separate from requested speech restrictions and show what is being agreed to.\n\nUnknowns: This is an adjacent silencing mechanism, not a psychiatric-detention example.\n\n## An account of harm becomes a claim of group deterrence\n\nAn individual retaliation event is interpreted as evidence that a wider group stops reporting.\n\nSupporting material: NRC individual enforcement and separate chilled-environment records provide different evidence streams\n\nContrary material: NRC reported no evidence of chilling in the cited FPL review; an individual finding does not settle group effect.\n\nWhat to look for: Code individual harm, expressed fear, actual reporting behavior and group findings separately. A drop in complaints has multiple explanations.\n\nAccountable practice: Evaluate whether people can safely complete and follow up a report; never treat fewer reports as proof of improvement.\n\nUnknowns: No reviewed dataset causally joins psychiatric referral to a measured group-wide decline in reporting.\n\n## A correction exists but the older claim still circulates\n\nA later correction does not replace every derivative summary or decision based on the earlier claim.\n\nSupporting material: Texas SB359 and Arizona HB2744 corrections in the research record; Diaz-Robainas penalty payment resolved after Edition03 marked it unknown\n\nContrary material: Preserving an old version is legitimate when visibly marked historical and linked to the correction.\n\nWhat to look for: Identify a concrete stale assertion and its dependency. Research-document examples do not establish the same failure in every product.\n\nAccountable practice: Link corrections to affected claims, patterns and instruments; distinguish corrected source from notified recipient.\n\nUnknowns: This pattern is observed in the compilation process itself; product applicability remains a design hypothesis.","published_text_sha256":"52492fc4bf3e637843028b6eaeeb45d0beed76ade4a3b5111c545d5301c4204c"},{"id":"DOC-8a55108039e0986b","title":"Expanded research questions","source_sha256":"bc1458c5c0ac0a0d3e78d4ce998d47626b88a8be2c14b4c3c82cc69840734e3b","visibility":"public edited research text","text":"## Shift from issue to reporter\n\nAnchors: Petitt and Diaz-Robainas. Record the safety issue, decision-maker knowledge, referral proposal and stated grounds separately. Inquiry into fitness is not itself proof of retaliation. Griffin and Mandreger supply contrary outcomes. Personal comparison requires the actual safety report and any actual subsequent referral or threat; presently unspecified.\n\n## Decision contemplated before its stated trigger\n\nAnchor: Petitt's record, as summarized in the supplied Batch19, contains proposed fitness scrutiny before the meeting later advanced as justification. This is more informative than timing alone. Obtain contemporaneous emails or notes; distinguish discussion from authorization and execution.\n\n## Grounds that change over time\n\nCompare first explanation, later explanation, clinical assessment and tribunal findings. Changed grounds can reflect new evidence or pretext; preserve both possibilities. A timeline must record when each fact became known, not merely when later accounts were written.\n\n## Independent disagreement\n\nAnchors: Petitt and Meeker. Independent clearances can contradict an asserted need for restriction, but scope, date and new evidence matter. Do not count multiple reports based on one interview as independent corroboration.\n\n## Order or threat without examination\n\nDiaz-Robainas concerns a psychological evaluation order and dismissal for refusal; an examination did not occur. The coercive effect of an employment condition must remain distinct from physical detention. Track threatened, ordered, attempted and performed actions separately.\n\n## Evaluation becomes restriction or repeated demand\n\nMeeker illustrates counseling required after fitness clearances, with an unlawful requirement finding. Preserve the difference between voluntary care, a condition of work, and involuntary admission. One adverse outcome does not establish every follow-up demand was improper.\n\n## Record transmitted to another authority\n\nPetitt provides an account of communication to a regulator. Identify exactly what was transmitted, its status, recipient, purpose and legal basis. An inaccurate record remaining at the original institution differs from an actual downstream disclosure. Correcting the first copy does not prove the recipient received a correction.\n\n## Redress controlled by the institution challenged\n\nArizona oversight material records concerns and limits on investigation. COPR and county advocates have functions even where they cannot order release. Record who receives a grievance, who investigates, who controls evidence, who decides, and available review. Do not turn an unsubstantiated grievance into either proof of misconduct or proof that nothing happened.\n\n## The professional who objects is targeted\n\nNEW: Murphy v. U.S. Department of Veterans Affairs, D. Maine,23Aug2013. Nurse Amber Murphy alleged retaliation after objecting to a patient's involuntary commitment. The court denied dismissal/summary judgment at that stage and expressly distinguished pleaded facts from the defendants' opposing account. This was not a final liability finding and not a finding that Murphy was hospitalized. Later disposition remains unlocated. It expands the inquiry to the treatment of staff who challenge an intervention affecting someone else. Source, pages1–4 and concluding order: https://www.govinfo.gov/content/pkg/USCOURTS-med-1_12-cv-00379/pdf/USCOURTS-med-1_12-cv-00379-0.pdf\n\n## A procedural barrier is treated as a universal absence of remedy\n\nNEW: Rawson v. Recovery Innovations,9thCir.2020, reversed summary judgment on state-action grounds. Under those facts, a private psychiatric provider acted under color of state law. Wrongful detention, forced medication and misleading the court were the underlying allegations, not all finally proved by that appellate ruling. This qualifies any blanket claim that private facilities cannot face federal civil-rights claims. No safety-whistleblowing trigger is established. Later merits outcome remains unlocated. Source: https://law.justia.com/cases/federal/appellate-courts/ca9/19-35520/19-35520-2020-09-09.html\n\n## Merits decision precedes practical repair\n\nDenhof, Petitt and Diaz-Robainas require separate remedy histories. The NRC's1997 record confirms the Diaz-Robainas $100,000 penalty was paid3Dec1996. That payment is not evidence of the employee's confidential settlement compensation or resolution of the original technical concern. Source: https://www.govinfo.gov/content/pkg/FR-1997-09-12/pdf/97-24220.pdf (footnote5)\n\n## Resolution adds restrictions on speech\n\nDelcore is an adjacent case about proposed settlement restrictions; not psychiatric detention. The actual proposed wording and governing context matter. Confidentiality and unlawful suppression cannot be equated without analysis.\n\n## Prior labels affect later credibility\n\nThe record raises this concern, but there is no general rule that hospitalization makes testimony inadmissible or incredible. The Robinson witness case involved mother-initiated commitment and particular credibility evidence. Judicial findings, evidentiary relevance and strategic misuse are different questions.\n\n## Complaint persistence is interpreted as incapacity\n\nRichards, Washburn and the querulous-complainant literature need their corrections attached. Persistence alone does not establish incapacity. Richards included appellate reversal and an agreed examination. Washburn involved clinical material, not filing volume alone. No pattern classifier should infer mental condition from report count, wording, repetition or frustration.\n\n## Fear alters reporting\n\nSeparate stated fear; withholding information; delayed reporting; actual reporting decline; and an official group-level chilling finding. It does not establish that he stopped reporting, nor group-wide effects. Historical individual retaliation findings and NRC group-environment records are separate evidence streams. Lower complaint numbers could reflect improvement, loss of access, fear or measurement changes.\n\n## The original issue disappears from the available decision\n\nEmployment litigation may decide retaliation without deciding the technical hazard. Mark 'not stated in reviewed source,' not 'ignored by everyone.' Retrieve the safety investigation separately. In Petitt, the reported commute-time policy change needs the FAA source; a secondary report does not resolve every safety allegation.\n\n## Multiple summaries appear to corroborate one account\n\nClaude, this thread, news coverage and a digest may all derive from the same judgment. Track source lineage before counting agreement. Independent corroboration requires a genuinely separate evidentiary basis, not another author or model.\n\n## Correction does not reach the working conclusion\n\nTexas2015 SB359 was vetoed; Arizona2024 enacted text differed from introduced text; the penalty payment was initially missed. Keep a dependency list from corrected claim to case summary, pattern and proposed instrument. 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