The plaintiff was a 59-year-old woman who had been a practicing Christian Scientist for approximately 10 years. She was unmarried and on welfare. She was involuntarily admitted to Bellevue Hospital by the police when she would not leave her hotel room. Upon admission, she was examined by two psychiatrists and certified according to New York law for commitment for 60 days. The plaintiff informed the hospital staff of her religious preference and that, based on these beliefs, she was unwilling to receive medical treatment. Over her objections she was given tranquilizers. She was never adjudicated mentally ill or incompetent prior to the treatment. The plaintiff brought an action under federal civil rights statutes, claiming damages for violation of her right to freedom of religion under the First Amendment. Can an individual be determined mentally ill and treatment initiated without an adjudication of incompetence?