In Kremens v. Bartley (1976), the U.S. Supreme Court ruled on a case involving minors who had been involuntarily committed to state mental hospitals in Pennsylvania without any form of hearing or trial, and were seeking release through habeas corpus petitions. The plaintiffs argued that their commitment violated their constitutional rights under the Fourteenth Amendment's due process clause. However, while the case was pending before the Supreme Court, Pennsylvania changed its laws to provide for hearings prior to involuntary commitments of minors and allowed those already committed an opportunity for review at a hearing. As such, the court found that these changes rendered much of this dispute moot because they provided remedies for many issues raised by plaintiffs' complaints about past practices under old law which no longer existed.

In the dissenting opinion for Kremens, Hospital Director, et al. v. Bartley et al., Justice William Brennan disagreed with the majority's decision to dismiss the case as moot and argued that it should have been decided on its merits. He believed that there was a reasonable expectation that these circumstances would recur in future cases involving minors who are involuntarily committed to mental institutions without due process of law or parental consent. Furthermore, he contended that this issue is capable of evading review because minors could be released before their legal challenges can be fully adjudicated by courts given how quickly such situations change. Therefore, according to Justice Brennan, dismissing this case as moot avoided addressing an important constitutional question about children's rights and procedural safeguards in involuntary commitment proceedings.