Joyce Patricia Brown

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Joyce Patricia Brown (perhaps better known as Billie Boggs) was a homeless person who defeated New York City's efforts to force her into a psychiatric treatment program. Her case set legal precedents for forced psychiatric care which have hamstrung involuntary psychiatric commitments of the homeless in New York and elsewhere.

In late 1987, NYC Mayor Ed Koch announced a new program for removing mentally disturbed homeless people from the streets, based on a state law allowing involuntary hospitalization of mentally ill people who were considered dangerous. Brown was the first homeless person to be involuntarily committed to a treatment program under the new program.

Brown was born on September 7, 1947 and became a secretary, living with her parents until they died in 1979, and then living with her sisters. She reportedly admitted to drug abuse including heroin and cocaine, and was arrested for an assault in Newark, New Jersey in 1982. In 1985, her sisters took her to East Orange General Hospital for a psychiatric evaluation, where she was diagnosed as psychotic, was treated with antipsychotic medications, and was put in restraints after attempting assaults on the staff. In May, 1986, after an argument, she left her sisters' home and apparently became homeless.

Brown had lived on a hot air vent grate near Second Avenue at 65th Street near a Swensen's Ice Cream Shop for about a year prior to her 1987 commitment. She was involuntarily committed to Bellevue Hospital on October 28, 1987 after a series of incidents which purportedly included running into traffic, exposing herself to passersby, making threats, tearing up and urinating on money that passersby gave her, and covering herself in her own excrement. She gave false names including "Ann Smith" and "Billie Boggs" (after Bill Boggs, a former local television talk show host in New York City), later claiming in court that she gave the false names to try to hide herself from her sisters. (Her sisters had been looking for her for some time, and went to Bellevue to identify her after recognizing court sketches of Brown in the news after her involuntary commitment.)

During Brown's 1987-1988 commitment and trial, Dr. Francine Cournos, a Columbia University assistant professor of psychiatry, testified that Brown was mentally ill.

Robert Levy, a staff attorney from the New York Civil Liberties Union (a state ACLU branch), defended her in court. On January 15, 1988, State Supreme Court Justice Irving Kirshenbaum ruled that New York City could not forcibly medicate Brown. Shortly thereafter, Acting State Supreme Court Justice Robert Lippmann ordered her released, in part because although she was mentally ill, her behavior was not obviously and immediately dangerous to anyone. She was released in late January after about eleven weeks of involuntary commitment and returned to the streets.

In 2000, the New York Daily News reported that Brown attended a talk sponsored by the Institute for Community Living. The article, which described Brown as "formerly homeless," stated she was continuing to receive drug counseling and had recently suffered a stroke.[1]

The Social Security Death Index [1] reports that Brown died on November 29, 2005.


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