In the case of Mills et al. v. Rogers et al., 1981, the U.S Supreme Court addressed whether a state could medicate mentally ill patients against their will under its police and parens patriae powers without violating their constitutional rights. The court held that while states have considerable discretion in determining the nature and scope of patient's rights, they cannot constitutionally authorize involuntary treatment by means less intrusive than necessary or deny a patient's right to refuse treatment entirely for nonemergency situations. However, it also ruled that federal courts should abstain from making unnecessary constitutional rulings when there are pending state proceedings involving important state interests such as mental health care provision.

In the dissenting opinion for Mills v. Rogers, Justice William Rehnquist argued that the majority's decision to remand the case back to state court was unnecessary and a misinterpretation of federal law. He contended that there were no significant constitutional issues at stake in this case, as it primarily involved questions about Massachusetts' mental health laws rather than broader civil rights concerns. Furthermore, he believed that even if such issues did exist, they should be addressed by state courts first before being brought to federal level. He also criticized the majority for not providing clear guidance on how lower courts should handle similar cases in future.