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The advocacy for rights for disabled students started with the class action lawsuit of the parents of Willowbrook residents, stating that those residents had 'a constitutional right to be free from harm within this facility'. It highlights institutions today, and agencies that were created for the protection of disabled people.

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Willowbrook 51 Years Later: A look at history and modern advocacy - Disability Rights

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A 1972 exposé by Geraldo Rivera exposed the revolting conditions at the Willowbrook State School, a facility for youth with intellectual disabilities, in Staten Island, New York. The abuse and neglect revealed by this report led to national outcry, successful legal action, and the establishment of a federally mandated network of legal advocacy agencies protecting the rights of persons with disabilities (the Protection & Advocacy Network). 51 years since the exposé’s release, Protection & Advocacy (P&A) agencies, like Disability Rights Tennessee (DRT), are continuing this critical work of investigating conditions of abuse and neglect, reporting these findings, and advocating for workable solutions.

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The horrific conditions in which willowbrook residents lived under was made public, allowing people who were not aware before become knowing of what was happening behind closed doors at the Willowbrook State Developmental Center. This was a stepping stool for modern day advocacy for disabled peoples rights and quality of care.

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New York State Association for Retarded Children v. Carey

A watershed case in the evolution of the legal rights of people with disabilities to live in dignity arose out of public awareness of the horrific conditions under which children and adults with disabilities were living at the Willowbrook State Developmental Center in New York. This case set important precedents for the humane and ethical treatment of people with developmental disabilities living in institutions. This, in turn, served as the impetus for accelerating the pace of community placements for people with developmental disabilities, expanding community services, increasing the quality and availability of day programs, and establishing the right of children with disabilities to a public education.

Inhumane Conditions at Willowbrook

Willowbrook was a complex of buildings on Staten Island housing children and adults with developmental disabilities. At its highest population, in 1969, 6,200 residents were living in buildings meant to house 4,000. Understaffed, overcrowded and underfunded, Willowbrook was little more than a "human warehouse," according to William Bronston, a physician at Willowbrook. The institution's overcrowding fostered abuse, dehumanization, and a public health crisis. Hepatitis was so rampant that several researchers took advantage of the situation to use residents as participants in a controversial medical study in which residents were intentionally exposed to the deadly virus, without their consent, in order to test the effectiveness of various vaccines.

In 1965, Senator Robert Kennedy paid an unannounced visit to Willowbrook. He found thousands of residents "living in filth and dirt, their clothing in rags, in rooms less comfortable and cheerful than the cages in which we put animals in a zoo." Kennedy went on to describe the institution as a "snake pit." The visit put conditions at Willowbrook into the national spotlight and the state of New York responded by developing a five-year improvement plan. However, after making minor adjustments, conditions at the institution quickly reverted to the inhumane conditions that had thrust it into public consciousness.

In 1972, ABC News investigative reporter Geraldo Rivera again drew national attention to Willowbrook with a television exposé that was watched by millions. Willowbrook: The Last Disgrace, exposed the institution's serious overcrowding, dehumanizing practices, dangerous conditions and regular abuse of residents. The public was again outraged. However, this time, the outrage served to spur parent advocacy groups to take action in federal court.

The Willowbrook Lawsuit

Following the Rivera exposé, parents of Willowbrook residents filed a class action suit in U.S. District Court for the Eastern District of New York on March 17, 1972. The lawsuit alleged that conditions at Willowbrook violated the constitutional rights of the residents. Parents outlined multiple violations, including:

Confining residents for indefinite periods;

Failing to release residents eligible for release;

Failing to conduct periodic evaluations of residents to assess progress and refine goals and programming;

Failing to provide habilitation for residents;

Not providing adequate educational programs, or services such as speech, occupational, or physical therapy;

Overcrowding;

Lack of privacy;

Failure to provide protection from theft of personal property, assault, or injury;

Inadequate clothing, meals, and facilities, including toilet facilities;

Confining residents to beds or chairs, or to solitude;

Lack of compensation for work performed;

Inadequate medical facilities; and

Understaffing and incompetence in professional staff.

The lawsuit sought immediate injunctive relief to improve conditions at Willowbrook, including hiring more staff, providing adequate medical care, prohibiting the use of seclusion and improper physical and chemical restraints, and providing adequate and appropriate clothing and physical conditions for residents. The plaintiffs alleged that the existing conditions violated the residents' constitutional right to treatment under the Due Process Clause of the Fourteenth Amendment, and that their denial of a public education violated the Equal Protection Clause of the Fourteenth Amendment.

In April 1973, U.S. District Court Judge Orrin G. Judd rejected the plaintiffs' arguments that the Due Process Clause guaranteed a right to treatment and that the denial of public education violated the Equal Protection Clause. However, he did find that the conditions in Willowbrook violated the constitutional right of persons living in state custodial institutions to be protected from harm. According to Judge Judd, the plaintiffs' constitutional right to protection from harm in a state institution meant that the residents of Willowbrook were "entitled to at least the same living conditions as prisoners." This right, he continued, "may rest on the Eight Amendment, the due process clause of the Fourteenth Amendment or the equal protection clause of the Fourteenth Amendment (based on irrational discrimination between prisoners and innocent mentally retarded persons)." Accordingly, Judge Judd granted much of the requested injunctive relief, including prohibiting the use of seclusions and restraints, increasing medical, therapeutic and recreational staffing, requiring maintenance, and requiring regular progress reports.

With this injunctive order in place, the case proceeded to trial on October 1, 1974, with the parties continuing negotiations for months afterwards. The case was settled on April 30, 1975, when Judge Judd signed the Willowbrook Consent Judgment: New York State Association For Retarded Children, Inc., et al., v. Hugh L. Carey, 393 F. Supp. 715 (1975).

The Willowbrook Consent Judgment

The Willowbrook Consent Judgment set forth guidelines and requirements for operating the institution and established new standards of care for all Willowbrook residents at the time of the settlement. These standards of care were "not optimal or ideal standards, nor... just custodial standards." They were based on the recognition that people with developmental disabilities, "regardless of the degree of handicapping conditions, are capable of physical, intellectual, emotional and social growth, and upon the further recognition that a certain level of affirmative intervention and programming is necessary if that capacity for growth and development is to be preserved, and regression prevented."

The Consent Judgment outlined specific procedures and instructions for treatment of residents, covering issues such as resident living, the environment, programming and evaluation, hiring of personnel, education, recreation, food and nutrition, dental and medical care, therapy services, use of restraints, conditions for residents to provide labor to the facility, and conditions for research and experimental treatment.

Significantly, the Consent Judgment also declared as the primary goal of the institution and the New York Department of Mental Hygiene to "ready each resident...for life in the community at large" and called for the placement of Willowbrook residents in less restrictive settings. The Consent Judgment set a goal of reducing the number of residents living at Willowbrook to no more than 250 by 1981 although this did not prove feasible.

Although the parties ended up in Court many more times in disputes over the ongoing implementation of the Consent Decree, it was, in a sense, fully implemented in 1987, when the Willowbrook State School and Hospital officially closed.

What Happened Next?

The political reaction to this case led to the enactment of legislation such as:

The Developmental Disabilities Assistance and Bill of Rights Act and CRIPA were the first federal civil rights laws protecting people with disabilities, leading to the enactment of the Americans with Disabilities Act (ADA).

Willowbrook Resources and References

Videos and Multimedia Resources

Articles and Other Secondary Sources

This article was originally printed in the December 2012 issue of The Federal Lawyer and is used with permission.

Opinions

District Court

Initial Injunctive Relief: New York State Association for Retarded Children v. Rockefeller, 357 F. Supp. 752 (1973)

Approval of Consent Decree: New York State Association for Retarded Children v. Carey, 393 F. Supp. 715 (1975)

Consent Decree

US Court of Appeals, Second Circuit decisions concerning implementation of Consent Decree:

References

1. The Minnesota Governor's Council on Developmental Disabilities, The ADA Legacy Project, Willowbrook Leads to New Protections of Rights, Moments in Disability History 9, 2013. Can be found at: ^http://mn.gov/mnddc/ada-legacy/ada-legacy-moment9.html

2. ^New York State Ass'n for Retarded Children, Inc. v. Rockefeller, 357 F. Supp. 752, 764 (1975).

3. ^New York State Association For Retarded Children, Inc., et al., v. Hugh L. Carey,. 393 F. Supp. 715 (1975) at ¶1.

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The Closing of Willowbrook - Disability Justice

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A watershed case in the evolution of the legal rights of people with disabilities to live in dignity arose out of public awareness of the horrific conditions under which children and adults with disabilities were living at the Willowbrook State Developmental Center in New York.

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This article talks about a woman who spent 16 years of her life in the institute after a misdiagnosis, and how she never truly recovered from how she was treated. Her daughter was the one who did the research into what exactly happened in willowbrook, and the conditions they were forced to live under.

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By the mid 1960s, Willowbrook, a Staten Island institution for mentally ill or delayed children, was filled to more than double its capacity. But crowding was the least of the horrors: Some residents of the state-run institution were reportedly used as test cases for hepatitis studies.

Others were left to languish, abused and living in squalor with little medical or mental health care. It wasn't until a print reporter named Jane Kurtin and then an aggressive 29-year-old investigative TV reporter - Geraldo Rivera - went in with hidden cameras that the world woke up to these forgotten children.

Now Vanessa Leigh DeBello tracks her mother's 16-year stay at the school in a new memoir Moron: A Daughter's Story of an Accidental Childhood in Willowbrook. "Moron" was one of three scientific terms established in the early 1900s for people with developmental delays. The strongest term was "idiot," followed by "imbecile."

So-called morons were considered high-functioning, and it was this opinion that doomed the Staten Island girl. At 18 months, the elder DeBello wasn't walking or talking. Her parents took her to a specialist, and after psychological exams and an IQ test that pegged her at 53 points, the recommendation was institutionalization. When she was 3, DeBello's parents dropped her off at Willowbrook, where she lived until she was 19 years old.

DeBello says her mother was always very open about her formative years at the New York school. DeBello remembers asking simple questions like "Did you have toothbrushes?" She says her mom recalled that basic necessities like toiletries were chronically missing. DeBello says her mother's mouth is filled with cavities. "I remember looking ... and seeing all that silver. 'Wow, look at that. When am I getting that?' "

But as she got older, DeBello learned not to envy her mother's past. Willowbrook was plagued by poor hygienic conditions. Residents suffered from skin rashes, DeBello says. There was constant poking and prodding with needles and an endless series of injections. When Robert F. Kennedy visited the school in 1965, he called Willowbrook a "snake pit." From the conditions her mother described, DeBello says, he was probably reacting as much to the smell as he was criticizing vicious and uncaring management.

Perhaps the most striking form of abuse is this: Some of the residents were deliberately exposed to hepatitis. Experts estimate that close to 100 percent of residents would have tested positive for the disease. Some contracted hepatitis through unsanitary drinking water, others were injected directly. Still others, DeBello says, were fed hepatitis-contaminated feces.

How could this happen? "The mentality was to put [these children] where we can't see them," DeBello says. She describes the Willowbrook campus - now used by the College of Staten Island - as isolated, with thick trees and a sense of being hidden. "Out of sight," she says, "it was also out of consciousness." Many parents left their children there and never came back.

Rivera's gripping TV coverage of conditions at Willowbrook not only helped shutter the institution, but also changed the way people were treated at such places nationwide. Willowbrook has been closed for more than 20 years. But DeBello says the site itself could be a more vivid reminder of what happened. Visit the former campus, she says, and you may not even know what happened. "There needs to be more education so we don't see something like Willowbrook ever happen again."

The legacy of Willowbrook remained alive in DeBello's mother. DeBello says her mother was always dressed poorly, even years after her discharge when she was married and had children. DeBello says she never achieved a sense of self-worth. "Take the credit card," her husband would say. "Go, buy something!"

No matter what, it will always remain true that DeBello's mother spent 16 grueling years at Willowbrook. The cruelest irony? "My mother was not mentally retarded," DeBello says. "She was misdiagnosed. She was an insider and was completely aware of the circumstances and abuse and neglect."

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Remembering an Infamous New York Institution

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At Willowbrook, a Staten Island institution for the mentally disabled, residents were left to languish in squalor with little medical or other care. Willowbrook closed in 1987. Now Vanessa Leigh DeBello has written a memoir about her mother's time there.

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Protection and Advocacy for People with Developmental Disabilities (PADD or P&A) supplies various services. care, and treatment after the exposure of the Willowbrook, to solidify how these sequences of events will not occur again.

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50th Anniversary of the Willowbrook Expose

This month marks the 50 th anniversary of the Willowbrook expose, a very important part of the disability rights movement. In 1972 Geraldo Rivera, a reporter, did an exposé called Willowbrook: The Last Disgrace,on the conditions at Willowbrook State School which was an institution for children with intellectual disabilities located on Staten Island in New York City from 1947 until 1987. Rivera exposed the institution's serious overcrowding, dehumanizing practices, dangerous conditions and regular abuse of residents. The school was designed for 4,000, but by 1965 it had a population of 6,000.

Following the exposé, there was public outrage, a lawsuit from parents of Willowbrook residents that alleged conditions at Willowbrook violated the constitutional rights of the residents, and a legislative push for change. The expose spurred NY state's senior senator, Jacob Javits, to action, incorporating the first P&A program - Protection and Advocacy for People with Developmental Disabilities (PADD) - in 1975 in the renewal of the Developmental Disabilities Assistance and Bill of Rights (DD) Act. There is a designated P&A in every state and territory. Disability Rights South Carolina is the designated P&A for South Carolina.

One key to making the P&A system successful was that Congress gave every P&A broad authority to access service providers that provide services, care, and treatment to people with disabilities. This includes, but is not limited to, schools, group homes, day programs, adult care homes, nursing homes, psychiatric hospitals, and residential treatment facilities. With our access authority we can go into any setting where services are provided, unannounced, to check in on the people who are there. The people who run these settings must allow us to come in and speak to anyone we want. We can ask questions and look for things that could hurt someone. We can also educate the individuals served and the staff about the rights of people with disabilities. Our access authority applies to both state-run and privately owned settings.

Congress made it clear that P&As were here to make sure Willowbrook never happened again. Since the beginning of the P&A system, Disability Rights South Carolina's core mission has been to stop and end the abuse and neglect of people with disabilities. Although, we have achieved a lot in the 50 years since this expose, we must also recognize there is much more still to do.
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50th Anniversary of the Willowbrook Expose - Disability Rights South Carolina

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This month marks the 50th anniversary of the Willowbrook expose, a very important part of the disability rights movement. In 1972 Geraldo Rivera, a reporter, did an exposé called Willowbrook: The Last Disgrace, on the conditions at Willowbrook State School which was...

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The residents were forced to face neglectful conditions, that overtime would cause harm. Budget cuts resulted in an inhuman cold 'institutional' setting. The caregivers tried to help the residents to the best of their ability, but being understaffed resulted in neglectful care.

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These changes were revolutionary. They can be linked to the placement of people with developmental disabilities in community residences, the growth of voluntary agencies, the expansion of special education and day programs, and the training of direct-care workers, therapists, teachers, and administrators.
Cover page for the class-action lawsuit that led to the Consent Judgement in 1975, listing the plaintiffs, made up of advocacy organizations and individual residents with their guardians.
Plaintiffs:
New York Association for Retarded Children, Inc.;
Benevolent Society for Retarded Children, Willowbrook Chapter, of the New York State Association for Retarded Children;
Lara R. Schneps, by her father Murray B. Schneps;
Nina Galin, by her mother Diana Lane McCourt;
Anthony Rios, by his father, Jesus Rios;
David Amoroso, by his mother Rosalie Amoroso;
Rose Evelyn Cruz, by her father Francisco M. Cruz;
Barry Friedman, by his father Melvin Friedman;
Lowell Scott Isaacs, by his father Jerome M. Isaacs;
Antoinette Magri, by her mother Sandra Magri.
Defendants:
Nelson Rockefeller;
Alan D. Miller, M.D.;
Roderic Grunberg, M.D.;
Robert E. Patton;
Charles Schleifer;
Jack Hammond, M.D.;
Robert W. Hayes;
Bertram Pepper, M.D.;
A. Anthony Arce, M.D.;
James M. Murphy, M.D.;
Manny Sternlicht;
Milton Jacobs, M.D.

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These changes were revolutionary. They can be linked to the placement of people with developmental disabilities in community residences, the growth of voluntary agencies, the expansion of special education and day programs, and the training of direct-care workers, therapists, teachers, and administrators.

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This article highlights how after about 50 years, the treatment of people with Developmental and intellectual disabilities has increased, but systemically issues still stand. Comparatively, the treatment of people with IDDs has improved since Willowbrook, but often reflects issues such as understaffed, bare minimums, or a lack in trained caregivers.

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50 Years After a Landmark Lawsuit, How Does NY Treat People With Developmental Disabilities?

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At the Willowbrook State School in Staten Island, children and adults with intellectual and developmental disabilities were beaten, experimented on, and left to suffer in deplorable, overcrowded,

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The advocacy for disabled people continues today, to increase the quality of care, and civil rights for disabled people. The author in the article calls for the continuous vigilance of advocacy, and how even today there are incidents in facilities. such as a facility in Rochester.

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Marilyn Parchus

I was very curious about this place called Willowbrook State School and its place in the history of New York State. Some of CDR's consumers lived at this state operated institution for children that were labeled as mentally-retarded or having developmental disabilities. I often wondered how the children got there and why? I decided to do some research on the subject.

The construction of Willowbrook State School was started in 1938, on a site of 375 acres on a section of Staten Island. Yes, right in the heart of New York, New York. It must have seemed to be such a noble concept at the time. We Americans pride ourselves in taking care of our own. And at that time, taking care of our own came to mean putting children with developmental disabilities into institutions.

Willowbrook's construction was completed in 1943. But it was opened as a United States Army Hospital and named Halloran General Hospital, after the late Colonel Paul Atacey Halloran.

After the war, proposals were introduced to turn the site over to the Veteran Administration, but in October, 1947 the New York State Department of Mental Hygiene opened the facility there as originally planned, as an institution named Willowbrook State School.

Hepatitis was quite common at the school. This led to a highly controversial medical study being conducted there between 1963 and 1966, in which healthy children were intentionally injected with the virus that causes the disease. Our United States doctors were again putting young citizens at risk for testing trial purchases. And the citizens being used were children with developmental disabilities.

The Hepatitis outbreak was so rampant that no new patients were admitted to the school, but the study was continuing to admit new patients. Parents found that they had to agree to the study in order to admit their children to the school.

Finally, public outcry forced the study to be discontinued because the parents and their children were given little choice about whether or not to participate in the research.

This was only the beginning of the atrocities at Willowbrook.

After a tour in 1965, Senator Robert Kennedy called Willowbrook a "snakepit", but even with this level of scrutiny, nothing was done to change the horrible conditions in which the children were forced to live.

In early, 1972, Geraldo Rivera, then a reporter for television station WABC in New York, conducted a series of investigations at Willowbrook uncovering a deplorable conditions, including overcrowding, inadequate sanitary facilities and physical abuse of residents by member of the school's staff.

These reports led to a class action lawsuit being filed against the State of New York in Federal Court on March 17, 1972. A settlement was reached on May 5, 1972, mandating reforms at the site, but several more years lapsed before violations were finally corrected.

The publicity generated by the case was a major contributing factor to the passage of a federal law, called the Civil Rights of Institutionalized Persons Act (CRIPA) of 1980. But even with these documented atrocities, and similar occurrences at many other institutions, it took many years to pass CRIPA and even longer to realize its intent.

After Willowbrook finally closed, it became the focus of a debate on what to do with the property. In 1989, a portion of the property was acquired by the City of New York, with the intent to us it to establish a new campus for the College of Staten Island. The new campus opened at Willowbrook in 1993. At 204 acres, this campus is the largest maintained by the City University of New York. The remaining 171 acres of the Willowbrook property at the south end, is still under the administration of the New York State Department of Mental Health, which maintains a facility there called the Institute of Basic Research in Developmental Disabilities.

To close Willowbrook and end the atrocities committed by the system and by individuals to a massive outcry from the public for change. Change did happen; the laws that came about shifted everything.

And while we say "never again", it could happen again, so we must never forget. Last summer, an investigation in a nursing facility in Rochester led to the arrest of over a dozen staff for their negligence leading to the death of a resident. We must be ever vigilant against the atrocities that happen to our people inside the seclusion of these facilities.

Our advocacy efforts and the power of our voices will bring about change. People must be able to choose where and how they live. We must be uncompromising in demanding the civil rights of all our people, or Willowbrook will happen again. We must FREE OUR PEOPLE!

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Marilyn Parchus I was very curious about this place called Willowbrook State School and its place in the history of New York State. Some of CDR's consumers lived at this state operated institution for children that were labeled as mentally-retarded or having developmental disabilities. I often wondered how the children got there and why?

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The lingering trauma and effects from Willowbrook still follows in the Human Services field. People from Willowbrook are still alive throughout New York and the Country. The trauma these people faced still follow today, and serves as a foundation for disabled peoples rights in the current day.

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Abuse and trauma among people with disabilities is something that I have deal with for seven years I have been in the Human Services field. People with all types of disabilities are considered a vulnerable population, especially those who have limited intellectual capacity. History is wrought with stories of abuses against individuals who have intellectual and developmental disabilities. Thankfully, there are now laws and agencies in place to offer protection from abuse and neglect. However, the trauma of the past is still apparent in many of the individuals who have survived.

Prior to about 1800, people with disabilities were seen as problematic. Individuals were cast away from their families, locked away in prisons or sanitariums, or completely ignored by general society because of their differences. It was not until the 19 th century that disabilities began to be studied and people began to take notice of the issues surrounding the treatment of the disabled. Institutionalism became increasingly popular and remained so until the 1970s. Willowbrook State School on Staten Island was one of these institutions that housed developmentally disabled children and became one of the major reasons for the institutionalization overhaul in the United States. Geraldo Rivera headed an exposé into the horrific living conditions of the 5000 children in Willowbrook (Office for People With Developmental Disabilities, n.d.). The severity of abuse and neglect in the institution was so awful that it prompted investigations into other institutions. The disabled children were kept in cribs constantly or housed in a single open area with no privacy. They were naked and sitting in their own excrement. To make matters worse, they were the subjects of state-sanctioned experiments that included feeding the children live hepatitis viruses. The effects of the abusive and neglectful treatment made already vulnerable and fragile individuals regress even farther into their disabilities, while others did not survive their time at the school. Those exposed to the despicable living conditions have had to overcome speech and language issues, behavioral issues, as well as serious medical implications from contracting hepatitis (Geraldo Rivera, 2017). The exposé by Rivera was only done in 1972, and many of the individuals from Willowbrook are still alive and living throughout New York State and other parts of the country (Office for People With Developmental Disabilities, n.d.).

One of the best achievements that came out of the tragedy of the institutions was the enactment of legislation to protect individuals with developmental and intellectual disabilities. In particular, the Developmental Disabilities Act of 1963, The Developmental Disabilities Assistance and Bill of Rights Act of 1975, and the Civil Rights of the Institutionalized Persons Act of 1980 (The ARC, n.d.). One of the most recent protections put into place in New York State was the establishment of the NYS Justice Center in 2012. The NYJS is designed "to protect the health, safety, and welfare of vulnerable New Yorkers." (The New York State Senate, 2015). Special accommodations are also made for the survivors of Willowbrook, including intensive case management. This case management has much stricter guidelines for monitoring and protecting the Willowbrook individuals than non-Willowbrook. These guidelines were put into place to help ease some of the effects of the trauma that the individuals were exposed to.

Protecting the rights and lives of individuals with intellectual and developmental disabilities is an ongoing process and the programs that serve these individuals are ever-changing to reduce the risk of abuse and neglect. Trauma can impact those with disabilities in different ways than people without disabilities and it is important to ensure that they have the necessary supports to both address trauma and to prevent it from happening as much as possible.

Office for People With Developmental Disabilities. (n.d.). Retrieved April 22, 2017, from https://opwdd.ny.gov/

Geraldo Rivera. (2017), From Geraldo's book, Willowbrook: A Report On How It Is And Why It Doesn't Have To Be That Way. Retrieved April 22, 2017, from http://geraldo.com/folio/willowbrook

The ARC. (n.d.). Public Policy and Legal Advocacy. Retrieved April 23, 2017, from http://www.thearc.org/what-we-do/public-policy/know-your-rights/federal-laws

The New York State Senate. (2015, October 05). Senate Passes Legislation to Protect People With Special Needs and Disabilities From Abuse and Neglect. Retrieved April 24, 2017, from https://www.nysenate.gov/newsroom/press-releases/senate-passes-legislation-protect-people-special-needs-and-disabilities
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People With Disabilities, Willowbrook, and Trauma

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Abuse and trauma among people with disabilities is something that I have deal with for seven years I have been in the Human Services field. People with all types of disabilities are considered a vulnerable population, especially those who have limited intellectual capacity.

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What happened at Willowbrook was a stepping stone for disabled people rights, and the foundation on which those rights were built upon. The inhuman treatment of disabled people, behind closed doors, was never to occur again. The rights to equal care and rights for disabled people are upheld today, with educational sections in school specifically designated to handle the needs of disabled students. Institutions today are carefully supervised, as opposed to Willowbrook, where the parents were unaware of what was occurring to their children after they dropped them off. The continuous vigilance of advocacy for disabled peoples rights, and equal care. The lingering trauma from what occurred at Willowbrook stands to set up a better future for disabled people, and make a better systemic standard in institutions.