In the case of O'Connor v. Donaldson, 1974, the U.S Supreme Court ruled that a state cannot constitutionally confine a non-dangerous individual who is capable of surviving safely in freedom by themselves or with the help of willing and responsible family members. Kenneth Donaldson had been confined in a Florida State Hospital for nearly 15 years against his will on grounds of mental illness despite never having been proven dangerous to himself or others. He filed suit against J.B O’Connor, among other hospital staff members alleging violation of his constitutional rights. The court held that mere public intolerance or animosity towards mental illness could not justify confinement; there must be legitimate government interest at stake such as preventing danger to community safety. This landmark decision emphasized protection for mentally ill individuals from unjustified invasion into their personal liberty and set significant precedent regarding involuntary commitment procedures.

In the dissenting opinion for O'Connor v. Donaldson, Justice Rehnquist argued that there was a lack of clear constitutional violation in the case. He contended that it was not within the jurisdiction of federal courts to intervene in state hospital practices unless there is an explicit breach of constitutionally protected rights. According to him, while involuntary confinement may be undesirable from a policy perspective, it does not necessarily equate to being unconstitutional if done under proper legal authority and due process. Furthermore, he expressed concern over potential implications this ruling could have on states' ability to manage their mental health systems effectively and efficiently without undue interference from federal courts.