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On January 3, 1999, a young woman named Kendra Webdale was tragically pushed to her death in front of an oncoming Manhattan subway train by twenty-nine-year-old Andrew Goldstein, a diagnosed schizophrenic with a history of violence who failed to take his prescribed medication.1 Other similarly tragic incidents occurred that year, including the April 6 police shooting of Charles Stevens, a man with a history of mental illness who swung a sword at passengers on the Long Island Railroad.2 In another instance, on April 28, 1999, Edgar Rivera's legs were severed after Julio Perez, an untreated schizophrenic, shoved him into an oncoming subway train.3 In response to these tragedies, New York's Attorney General, Eliot Spitzer, proposed Assisted Outpatient Treatment ("AOT") legislation, which is the official name for Kendra's Law.4 On August 27, 1999, New York Governor George Pataki formally signed this legislation, named in honor of Kendra Webdale, into law.5 This statute allows particular individuals to petition the court to obtain an order for a mentally ill person to receive AOT if that person meets very specific

A Constitutional Analysis of Kendra's Law: New York's Solution for Treatment of the Chronically Mentally Ill