Brondel v. Lenard

CourtDistrict Court, E.D. Missouri
DecidedMay 15, 2025
Docket4:25-cv-00546
StatusUnknown

This text of Brondel v. Lenard (Brondel v. Lenard) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brondel v. Lenard, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

WAYNE BRONDEL, ) ) Plaintiff, ) ) v. ) No. 4:25-cv-00546-AGF ) HELANA LENARD, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter is before the Court upon multiple filings by self-represented Plaintiff Wayne Brondel. On May 5, 2025, the Court received three documents from Plaintiff. ECF No. 3. To the extent these documents request emergency relief from the Court in the form of a preliminary injunction or temporary restraining order, they will be denied for the reasons discussed below. Plaintiff’s Filings Plaintiff is a civilly-committed offender being held at the St. Louis Forensic Treatment Center, a Missouri Department of Mental Health facility. Plaintiff’s first document is titled “Motion for Emergency Order.” ECF No. 3 at 1-5. In this undated motion, Plaintiff states that he is being “drugged” against his will. Id. at 1-3. Plaintiff “ask[s] this Court to please make a phone call and stop these forced drugs.” Id. at 2. Plaintiff attached a “Notice of Clinical Due Process Hearing,” dated April 25, 2025, stating Plaintiff’s treating psychiatrist, Asad Qalbani, had determined that Plaintiff needs to be involuntary medicated as part of his treatment and that a due process hearing on this decision would be held on April 28, 2025. Id. at 3. This notice also informed Plaintiff that he would hear evidence on the basis for his involuntary medication at the hearing, that he could ask questions, present evidence on his own behalf, and that he would be assisted at the hearing by a patient advocate. Id. Second, Plaintiff filed an untitled document dated April 26, 2025, complaining about the conditions of confinement at the Forensic Treatment Center in relation to access to legal books, handling of mail, and availability of hot water. Id. at 6-9. In this document, Plaintiff asks the Court to name a “legal rep” for Plaintiff and others being held at the Forensic Center. Id. at 7. This representative would not give legal advice but provide case numbers, contact information for

the Court, contact information for patients’ attorneys and guardians, and legal materials. Id. at 7- 8. The third document filed by Plaintiff is titled “Motion to Stop Forced Drugs” and dated April 29, 2025. Id. at 11-14. In this filing, Plaintiff references multiple cases that he has pending in the United States District Court for the Western District of Missouri.1 Plaintiff alleges that when the defendants named in his Western District cases received notice of Plaintiff’s case filings, they “retally ate” against him by forcing drugs on him. ECF No. 3 at 11. Next, Plaintiff appears to be describing his April 28th Due Process Hearing when he states: Mon at 1:00 PM meeting or hearing held. 100% no evidence presented, just all words, I in response stated all or allegations nothing on video will show in fact the video will show that allegation are false. Well believe it or not they decided to drug me I only got hours to appeal but I no longer have a patient advocate and I must call my attorney to come in and explain, yes 100% what they are doing.

Id. at 11-12. In conclusion, Plaintiff asks the Court “to please stop the drugs being forced upon” him. Id. at 13.

1 One of the cases referenced by Plaintiff is Brondel v. Thumann, No. 2:25-cv-04068-BCW (W.D. Mo. filed Apr. 7, 2025). Based on a review of this case on PACER, the federal court public access system for electronic court records, Plaintiff challenges his civil confinement and refers to a Missouri circuit court order that Plaintiff be held “6 month[s] or longer” as a “mental health commit” on March 24, 2025. Id. at ECF No. 1. The Court notes that the Missouri court that ordered Plaintiff’s confinement is Callaway County, Missouri, which is located in the jurisdiction of the Western District. See 28 U.S.C. § 105 (b)(4). Discussion I. Legal Standard for Preliminary Injunction or Temporary Restraining Order The Court construes these pleadings as requesting a preliminary injunction or temporary restraining order to prohibit the involuntary medication of Plaintiff.2 “Whether a preliminary injunction should issue involves consideration of (1) the threat of irreparable harm to the movant;

(2) the state of the balance between this harm and the injury that granting the injunction will inflict on other parties litigant; (3) the probability that movant will succeed on the merits; and (4) the public interest.” Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109, 113 (8th Cir. 1981). These factors are also considered to determine the propriety of a temporary restraining order. See S.B. McLaughlin & Co., Ltd. v. Tudor Oaks Condo. Project, 877 F.2d 707, 708 (8th Cir. 1989). “In balancing the equities no single factor is determinative.” Dataphase, 640 F.2d at 113. The relevant inquiry is “whether the balance of equities so favors the movant that justice requires the court to intervene to preserve the status quo until the merits are determined.” Id. The burden of proof is on the party seeking injunctive relief. Gelco Corp. v. Coniston Partners, 811 F.2d 414,

418 (8th Cir. 1987). In addition, “[a] court issues a preliminary injunction in a lawsuit to preserve the status quo and prevent irreparable harm until the court has an opportunity to rule on the lawsuit’s merits. Thus, a party moving for a preliminary injunction must necessarily establish a relationship between the injury claimed in the party’s motion and the conduct asserted in the complaint.” Devose v. Herrington, 42 F.3d 470, 471 (8th Cir. 1994) (internal citation omitted).

2 To the extent Plaintiff complains about conditions of confinement such as access to legal materials, hot water, and mail, he does not seek any immediate relief in regard to these conditions, so the Court does not construe these issues as relevant to the request for emergency relief here. II. Forced Medication Under the Fourteenth Amendment The question as to whether a state may forcibly medicate a civilly committed individual has both substantive and procedural aspects. See Washington v. Harper, 494 U.S. 210, 220 (1990). “The substantive issue involves defining the protected constitutional interest, as well as identifying the conditions under which competing interests may outweigh it,” while the “procedural issue

concerns the minimum process required by the Constitution.” Morgan v. Rabun, 128 F.3d 694, 696 (8th Cir. 1997). In other words, “the substantive issue is what factual circumstances must exist before the State may administer antipsychotic drugs to the prisoner against his will; the procedural issue is whether the State’s nonjudicial mechanisms used to determine the facts in a particular case are sufficient.” Harper, 494 U.S. at 220. Regarding the substantive component, the Due Process Clause of the Fourteenth Amendment gives an individual “a significant liberty interest in avoiding the unwanted administration of antipsychotic drugs.” Id. at 221-22. As such, the state is permitted to treat a seriously mentally ill inmate with antipsychotic drugs against his will if the inmate is a danger to

himself or others, and the treatment is in the inmate’s medical interests. Id. at 227. See also Morgan, 128 F.3d at 697 (explaining that with regard to substantive due process, a committed individual’s due process rights are not violated if he is a danger to himself or others).

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Related

Washington v. Harper
494 U.S. 210 (Supreme Court, 1990)
Dataphase Systems, Inc. v. C L Systems, Inc.
640 F.2d 109 (Eighth Circuit, 1981)
Clay Thomas v. Scott Eschen
928 F.3d 709 (Eighth Circuit, 2019)
Devose v. Herrington
42 F.3d 470 (Eighth Circuit, 1994)
Gelco Corp. v. Coniston Partners
811 F.2d 414 (Eighth Circuit, 1987)

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Brondel v. Lenard, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brondel-v-lenard-moed-2025.