Meanwhile, a series of court cases in the 1970s established the right of people to treatment and habilitation in the least restrictive environment.
Wyatt v Stickney in Alabama, then Welsch v Likins in Minnesota and United States v Solomon in Maryland resulted in federal district court decisions that established the right to treatment in the least restrictive environment.
In 1975, Geraldo Rivera exposed conditions in Willowbrook State School and the Willowbrook decision (New York ARC v Carey) escalated the language to include "and the most normal living condition possible."
The decision was based on the Eight Amendment right to be free from cruel and unusual punishment. Willowbrook closed in September 1987.