[1] John Rennie, age 38, was a former pilot and flight instructor who was a patient at Ancora Psychiatric Hospital in Winslow Township, New Jersey.

Rennie sued in federal district court to prevent the hospital from administering psychotropic medications to him without a clear emergency.

Rather than enjoining the hospital from giving him any medication, he insisted that the prolixin be lowered to a minimum maintenance dosage, which staff psychiatrists considered too low.

Several months after issuing his initial ruling that asserted a right to refuse treatment grounded in a constitutional right to privacy, Judge Brotman made the case into a class action that included all involuntarily committed patients at the five mental health facilities operated by the state of New Jersey, and held an additional seventeen days of hearings.

New Jersey's administrative policies, which provide for a second psychiatric opinion in the case of refusing patients, must give adequate scope for the exercise of that right to satisfy constitutional requirements.

[3] However, as this case illustrates, applying the least restrictive principles and working with a patient on medication choices brings up difficult empirical issues in ranking treatment options in accord with constitutional rights.