The U.S. Supreme Court case Parham v. J.R., 1978, centered on the rights of parents and children in decisions regarding mental health treatment for minors. The court was asked to decide whether Georgia's statutory scheme which allowed parents or guardians to commit their minor children to a state mental hospital without formal hearings violated the Due Process Clause of the Fourteenth Amendment. In a 5-3 decision, the court ruled that while children have constitutionally protected interests at stake, they are not necessarily identical or equal to those of adults in similar situations. It held that parental authority is not absolute but carries with it high responsibility and discretion; thus, there must be substantial evidence showing "need for aid" before a child can be institutionalized against his will or without his consent beyond immediate control period (usually about two weeks). However, it also stated that an independent review by a neutral factfinder is required when admission extends beyond this short term.

In the dissenting opinion for Parham v. J.R., Justice Brennan, joined by Justices White and Marshall, argued that children should have a right to an adversarial hearing before being committed to a mental institution. They believed that the majority's decision did not adequately protect children from erroneous commitment decisions made by their parents or state officials. The dissenters felt that while parents generally act in their child’s best interest, there are instances where this may not be true - such as when parental judgment is clouded due to emotional stress or other factors. Furthermore, they pointed out potential conflicts of interest within state institutions which could lead to unnecessary commitments for financial gain or convenience rather than genuine medical need. Therefore, they contended that an independent review process was necessary to safeguard against these risks and uphold the constitutional rights of minors.