Involuntary hospitalization of Joyce Brown

Brown being released from Bellevue in 1988.

Joyce Patricia Brown (1947 – November 29, 2005), also known as Billie Boggs, was a homeless woman who was forcibly hospitalized in New York City in 1987. She was the first person hospitalized under a Mayor Ed Koch administration program which expanded the city's ability to forcibly commit homeless New Yorkers to psychiatric hospitals. Between 1987 and 1988, Brown worked with the New York Civil Liberties Union to challenge her hospitalization in a case which attracted significant media attention. During the ensuing trial, her lawyers argued that her behaviors were not in line with social expectations but did not rise to the level of posing a danger to herself or others. Brown took the stand, and her clarity while testifying became part of the public conversation. The trial ended in her favor, and while the city won on appeal she was ultimately released after a subsequent case determined that the city could not forcibly medicate her. Following her release, she made several television appearances and spoke about homelessness at Harvard Law School, but came to avoid the press. Her case sparked national conversations about how best to care for the people with mental illnesses.


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