Overall, the cases pursuing a right to treatment met promising victories. In 1966, the U.S. Court of Appeals for the District of Columbia recognized the right to treatment in Rouse v. Cameron, when Chief Judge David Bazelon ruled that a right to treatment existed at the statutory level, mandating treatment for a patient committed to St. Elizabeths Hospital. In 1971, in Wyatt v. Stickney, U.S. District Court Judge Frank M. Johnson, Jr., held that involuntarily civilly committed patients are entitled to adequate care and treatment or else they are being deprived of their liberty without due process of law, as required by the Fourteenth Amendment to the U.S. Constitution. The Wyatt court decided that the treatment at Bryce Hospital was grossly deficient and failed to satisfy minimum medical and constitutional standards. Not only was the right to treatment recognized, but the court then ordered a mechanism for enforcement and implementation of the right, which included formal hearings at which amici curiae could submit proposed standards for adequate treatment. In 1974, in Donaldson v. O'Connor, the Fifth Circuit recognized a constitutional right to treatment. However, upon appeal, the Supreme Court did not rule on the constitutionality of the right to treatment and instead decided the case on narrower grounds. Therefore, a definitive legal standard of care for patients afflicted with mental illness has yet to be established at the Supreme Court level.