In the wake of the World Health Organization, World Psychiatric Association and European Psychiatric Congress condemning coercive psych practices, a mental health watchdog asks why an APA Meeting has failed to do the same.

By CCHR International
The Mental Health Industry Watchdog
April 26, 2024

Citizens Commission on Human Rights (CCHR) International has taken the American Psychiatric Association (APA) to task for its failure to issue a formal position statement condemning the use of coercive psychiatric practices, as its peer groups have already done. Since 2020, CCHR has put the APA on notice of the global concern about forced psychiatric institutionalization and treatment, which is rampant in the U.S. CCHR’s demands coincide with the annual meeting of the APA being held in New York, May 4-8—a city which has been criticized for its coercive approach to involuntary commitment, compulsory community mental health treatment, high restraint use and forced electroshock therapy.

In 2020, the World Psychiatric Association (WPA) issued a “Position Statement and Call to Action: Implementing Alternatives to Coercion: A Key Component of Improving Mental Health Care.”  It stated its concern about “the extent to which coercive interventions violate” human rights and recognized practices that constitute coercion to include formal (involuntary) detention, treatment without consent, seclusion and restraint use.[1]

In April 2024, the European Congress of Psychiatry held a special seminar for its attendees on reducing coercive measures in psychiatry—something CCHR has several times asked the APA to do at its annual meeting. Medscape reported on the European seminar, titled, “Coercion in psychiatry: Epidemiology and Prevention,” which was addressed by Julian Beezhold, MD, a consultant in emergency psychiatry for Norfolk and Suffolk National Health Services (NHS) Foundation Trust in England. He emphasized the importance of the shift away from coercion because of its risks. Coercive practices ranged from physical restraints to social and emotional pressure.[2]

Yet the APA formally endorses involuntary commitment as a “useful tool to promote recovery.” Its position statement on the practice effectively sets out court-mandated treatment programs (often referred to as “assisted outpatient treatment,” or AOT), that should occur for extended periods of time and “should last at least 180 days, with extensions possible after judicial review.”[3] That’s nearly half a year of potentially forced, coercive treatment.

CCHR directed the APA to the joint Guideline on Mental Health, Human Rights and Legislation that the World Health Organization (WHO) and United Nations Office of the High Commissioner for Human Rights (OHCHR) issued in October 2023. The guideline condemns coercive practices defined to include, “involuntary hospitalization, involuntary medication, involuntary electroconvulsive therapy (ECT), seclusion, and physical, chemical and mechanical restraint.”[4] These “violate the right to be protected from torture or cruel, inhumane and degrading treatment….”[5] The report further states, “There is evidence that legislative changes can help prevent involuntary commitment and direct it towards abolition” and that “legislation can prohibit all involuntary measures and mandate that all services, outpatient or inpatient, implement non-coercive responses.”[6]

• In the U.S., according to David Cohen, a professor of social welfare at the UCLA Luskin School of Public Affairs in California, involuntary psychiatric detentions outpaced population growth by a rate of 3 to 1 on average in recent years.[7]

• A study published in The American Journal of Psychiatry citing figures from 2014 suggests that involuntary hospitalizations account for 54% of admissions to psychiatric inpatient settings.[8]

Jan Eastgate, President of CCHR International, says, “The fact that the APA chose New York to hold its congress says a lot about supporting, rather than working towards eliminating coercion.” She pointed to the fact that in 2023, New York had the second-highest amount invested in mental health in the country at $4.95 billion, with California leading at $6.76 billion.[9] Yet “New York has among the highest rates of coercive psychiatric practices.”

• According to a Democrat & Chronicle report, patients at 13 hospitals statewide were being placed in restraints at rates above the national average. Mental health patients in New York spent a total of nearly 11,900 hours in restraints and 9,000 hours in seclusion while in psychiatric units in 2021, the latest federal data showed. It said that “the true scope of restraint use −and misuse − at hospitals remains shrouded in secrecy because the techniques are only tracked for psychiatric units under state and federal laws.”[10]

• The USA Today Network found, “Thousands of patients are restrained in emergency rooms and other hospital wards across New York with limited independent oversight.” Further, “At least 50 hospital patients were improperly restrained in New York between 2015 and 2018, spanning men and women handcuffed, hit with batons, drugged and left strapped to beds up to 12 hours without regular check-ups and water.”[11]

Forced Community “Treatment” and Threatened Incarceration

In 1999, New York enacted a law known as Kendra’s Law, named after Kendra Webdale, who was killed when Andrew Goldstein, with a long history of failed psychiatric treatment, pushed her into the path of an oncoming subway train. As The Guardian reported, Kendra’s Law “gives courts the authority to force people who have “a history of lack of compliance with treatment for mental illness” into “assisted outpatient treatment.” Individuals who don’t comply can face detainment by law enforcement or involuntary hospitalization—i.e., involuntary commitment.[12]

Goldstein, who was sentenced to over 20 years in prison, had been hospitalized 13 times—voluntarily—and each time he was drugged and discharged. Shortly after Webdale’s death, Michael Winerip, a reporter for the New York Times, was given Goldstein’s 3,500-page psychiatric file from “people who see his treatment record as a harrowing testament to the failures of the mental-health system.” In the two years leading up to Kendra’s death, Goldstein had attacked at least 13 other people.[13] 

Yet, the “solution” was to amend the law to force people to undergo psychiatric treatment—often with drugs documented to cause violence—or be threatened with being institutionalized. These treatments may have contributed to Goldstein’s violent behavior, ultimately indirectly leading to Kendra’s death.

• Instead of involuntary admission based on the usual violent or dangerous behaviors that may cause harm to themselves or others, individuals can now be involuntarily admitted to New York psychiatric hospitals if they display an inability to meet their basic living needs.[14]  Paul Appelbaum, a former APA president, and Thomas Gutheil, who both support involuntary commitment, call it a “human right to health care,”[15] a statement Eastgate says is disingenuous and misleading.

• Experts say involuntary psychiatric commitment often leads to the loss of access to basic rights and services, including employment, parenting, education, housing, professional licenses, or even potentially the right to drive, experts say.[16]

• The WHO/ OHCHR guideline stresses, “More recently, the UN Special Rapporteur stressed that purportedly ‘benevolent’ purposes, such as ‘medical necessity,’ ‘re-education,’ …do not vindicate coercive or discriminatory practices and may amount to torture. There is an immediate international obligation to end these practices.” There is also “limited evidence to support the success of coercion in reducing the risk of self-harm, facilitating access to treatment, or protecting the public.”[17]

Kendra’s Law enforces the Assertive Community Treatment (ACT) program, “one of the most coercive and intrusive psychiatric programs coordinated by New York State,” where “members of a treatment team can enter any sphere of a person’s life: in their work, school, play, and/or home spaces,” according to Lauren Tenney, Ph.D., MPhil, MPA.[18] “In addition to involuntary outpatient commitment being an assault on and targeting people who are living in or near poverty, the statistics demonstrate racial disparities—gross over-representation of people who are African American—in the application of involuntary outpatient commitment.”

Tenney’s compelling article in 2019, “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist revealed the following coercive practices in New York:

• One-fifth of people in the Assertive Community Treatment program are court-ordered through Kendra’s Law.

• Between 1999 and 2019, 27,128 petitions were filed for involuntary outpatient commitment, with 25,854 of the petitions granted—95%. There were 16,911 people under court-ordered psychiatry while living in the community, meaning “these people are living under the threat of re-institutionalization at any moment for noncompliance with the treatment ordered.” [19]

• Kenda’s law was expanded following a November 2022 Mayoral directive giving police officers, peace officers, mobile crisis outreach teams, and medical professionals the authority to involuntarily remove an individual from the community to a hospital to receive a psychiatric evaluation.

The law is contrary to international moves to outlaw forced treatment both in hospitals and in the community. The UN/UN Guideline notes:

• “The use of any coercive measure in all mental health services is prohibited, including medical and non-medical interventions without informed consent, the use of isolation rooms and chemical and mechanical restraints, and restrictions to free movement within health services…. Shackling, chaining, seclusion, restraints, and any other form of violence, and abuse against a person with mental health conditions and psychosocial disability in the community are prohibited.” [20]

Psychiatry Fuels Racist Coercion

In January 2021, the APA issued a public apology for what it said is psychiatry’s “role in perpetrating structural racism” and a “history of actions…that hurt Black, Indigenous, and People of Color” (BIPOC). Psychiatrists had subjected indigenous people to “abusive treatment, experimentation, victimization in the name of ‘scientific evidence,’ along with racialized theories that attempted to confirm their [mental/intellectual] deficit status.”[21]

And yet, it is holding its annual meeting in New York, with no comment on the coercive practices so evident there. Kendra’s Law has been widely criticized both for its lack of effectiveness in treatment and for the way it disproportionately affects New Yorkers of color.[22] 

• “The fact that the United States of America has a long and deeply disturbing history of enacting systems of slavery begs the question of the legitimacy of court-ordered psychiatry,” wrote Tenny. [23]

• Studies have found that people of color are more likely to be forced into treatment or hospitalization than whites—including in New York.[24]

• In 2022, nearly 4 out of 5 Kendra’s Law coercive treatment orders were applied to Black and Brown people in New York City.[25]

• In New York City more than half (54%) of people who have Assertive Community Treatment teams assigned to them are Black, and 23% are Hispanic.[26]

• Between 1999 and 2009 about 34% of AOT recipients had been African Americans who made up only 17% of the state’s population, while 34% of the people on AOT had been whites, who made up 61% of the population. A decade later, the disparities had grown: 30% of people under Kendra’s Law were White; 37% were Black; 27% were Hispanic; 4% were Asian.[27] [Note: a decade later refers to 2019–years between the study done in 2009 and the Office of Mental Health’s statistics from June 2019.]

Add to the Coercion the Barbarity of Electroshock Treatment

The WHO-OHCHR Guideline condemns the forced use of electroconvulsive therapy (ECT), most commonly known as electroshock or shock therapy, as violating “the right to be protected from torture or cruel, inhumane and degrading treatment….”[28] It noted, “there have been calls for it to be banned altogether,” which CCHR is a long-term advocate of.[29]

CCHR helped achieve the first ban of the use on minors in California in 1976 and Texas in 1993 but said the whole practice should be prohibited.

WHO/OHCHR “The right to free and informed consent is a fundamental element of the right to health. It encompasses the right to consent to, refuse or choose an alternative medical treatment.” [Emphasis added] “…no mental health treatment shall be given without such consent.”[30]

However, there is a provision for forced, coercive ECT: The NYS Office of Mental Health Guidance on Electroconvulsive Therapy notes it is a “controversial treatment, especially when provided by court order and over objection…. From a consumer perspective, court-ordered ECT may serve to worsen a long standing concern that mental health care is intrusive and paternalistic, and thus is not person centered.” However, pursuant to Rivers v. Katz, “The patient’s right to self-determination is deemed paramount to a physician’s obligation to provide medical treatment, as is a competent patient’s right of refusal for treatment.” But it allows for courts to override a patient’s objections.[31]

The Food and Drug Administration (FDA) warns, “Long-term safety and effectiveness of ECT treatment has not been demonstrated.”[32] In its Final Ruling on the ECT device in December 2018, the FDA erroneously stated that “involuntary ECT treatment is uncommon in the United States. In every State in the United States, the administration of ECT on an involuntary basis requires a judicial proceeding.”[33]

While it may be true for New York, there are 33 geographical jurisdictions including the District of Columbia and Puerto Rico where the state laws and administrative codes do not even comment on the use of ECT.[34]

The dearth of statistics on ECT’s usage in the United States is egregious given its serious risks. Even the FDA defers to a 1995 study—nearly 30 years old—that reported 100,000 Americans are given ECT every year.[35]

CCHR recently filed FOIA requests to all U.S. states for an update on their ECT use statistics under Medicaid, including how many are given it involuntarily. Of 22 states that responded, which did not include New York, CCHR researchers estimated that over 90% did not track ECT given to patients against their will. 

Failure to Inform How ECT Causes Brain Damage

Informed consent does not fare any better. One study in the United States reported the use of the informed consent form for ECT was never obtained 26% of the time.[36]

“Informed consent to ECT is a misnomer, grossly misleading consumers and their families to the point of consumer fraud,” Eastgate said.

WHO/OHCHR advise that minimally, patients “should also be made aware of all its risks and potential short- and long-term harmful effects, such as memory loss and brain damage.”[37]

• A sample of 12 websites of hospitals delivering ECT in New York revealed no mention of brain damage as an adverse effect, despite the recent WHO OHCHR Guideline warning about the risk of brain damage, citing a U.S. court case.[38]

• In that 2018 case, the judge determined: “A reasonable jury could find that the ECT device manufacturer caused Plaintiffs’ brain damage through failure to warn their treating physicians of brain injury, or alternatively by failing to investigate and report allegations of brain damage and permanent memory loss to the FDA, so that information would be available to the public.”[39]

• Somatics, an ECT device manufacturer admits that “patients may experience permanent memory loss or permanent brain damage.”[40]

• However, the American Psychiatric Association recommended brain damage be omitted from ECT consent forms.[41]

In omitting “brain damage,” psychiatrists are given license to assault patients, sanctioned by the State.

While conceding “the exact process that underlies the effectiveness of ECT is uncertain,” NY’s Office of Mental Health (OMH) fails to report that the FDA has never required ECT device manufacturers to conduct clinical trials proving safety and effectiveness.

• Rather, OMH forwards the provenly false theory that chemical imbalances in the brain are related to a mental disorder or treatment administered: “Biological changes that result from the seizure [ECT causes] are believed to result in a change in brain chemistry which is believed to be the key to restoring normal function.”[42] Very dated public statistics show that 26% of individuals subjected to ECT in 2000 were court-ordered.[43]

• One hospital in Buffalo claims, “A controlled seizure is induced to improve the chemical pathways in the brain that effect [sic] mood and behavior.” There’s no scientific evidence or test to prove it improves “chemical pathways.”[44]

• Another hypothesized statement is “ECT probably works by altering brain chemicals….”[45] Yet another asserted, “Experts do not entirely understand why the seizure is effective, but it’s thought that it eases the symptoms of depression by changing the brain’s chemistry….”[46]Still, another said the controlled electrical current used, “causes a mild brain seizure that can alter an individual’s brain chemistry by releasing chemicals in the brain and encouraging the brain cells to make new connections…Slight memory loss may last minutes to hours.”[47]

• Astonishingly, the Mount Sinai Hospital website reports: “Doctors believe that the seizure activity may help the brain ‘rewire’ itself, which helps relieve symptoms.”[48]

• In June of 2022, the esteemed medical journal Molecular Psychiatry published a study conducted by researchers with the Division of Psychiatry at University College London
  (UCL) that concluded with resounding finality that there is no causal relationship between a so-called “chemical imbalance” or “low serotonin” in the brain and depression or, for that matter, any chemical imbalance causing “mental disorder.” This finding was based on an analysis of depression-related studies from the past 30 years. [49]

Consumer Fraud

To imply that ECT changes chemicals in the brain to improve depression should be investigated for consumer fraud.

• Most websites claim the side effects of electroshock are minimal—even though, in reality, they are devastating. 

• ECT is not a “life-saving” medical treatment. A study published in Acta Psychiatrica Scandinavica last year found that after receiving electroshock, patients were 44 times more likely to die by suicide than people in the general population. [50] The fact that ECT does not prevent suicide but can also induce it and causes brain damage five further reason to ban it. 

• So ineffective is the treatment, that “maintenance ECT” and continuing “medication” is recommended.

Electroshock Causes Torture

The WHO/OHCHR Guideline says forced electroshock should be prohibited as it’s an act of torture.

The U.S. has ratified the UN Convention against Torture (CAT), adopting it in domestic law, but this is not evident in mental health laws. A Harvard Law School Project on Disability report, “When Does Mental Health Coercion Constitute Torture?” notes that to constitute torture, intent must be proved and, therefore, “individual mental health workers’ specific intent to inflict severe harm.” Because involuntary commitment laws empower psychiatrists to circumvent a patient’s right to refuse treatment, state mental health laws give license to intentional harm to be committed.[51]

This is another reason why laws must be changed to reinforce that because forced treatment constitutes torture when administered without consent is a violation of the Convention Against Torture and shows an intent to harm.

The APA’s annual convention program asserts, “Psychiatrists and mental health clinicians will join together to develop cutting-edge solutions to questions faced by professionals throughout the field.”[52]

Eastgate responded, “Without a commitment to end all coercive psychiatric practices, including forced hospitalization, drugging and electroshock treatment, there cannot be cutting-edge solutions because psychiatrists will keep peddling the same idea of forced treatment as ‘helpful,’ when it is tantamount to torture.”

The APA’s failure to condemn coercive psychiatric practices, despite calls from CCHR, remains a glaring gap in global mental health advocacy. While other associations have taken steps to denounce coercion, the APA’s silence persists, even as it convenes in New York. Urgent action is needed to implement non-coercive alternatives and uphold fundamental human rights of patients in the mental health system.

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[1] https://www.wpanet.org/alternatives-to-coercion; https://www.wpanet.org/_files/ugd/e172f3_635a89af889c471683c29fcd981db0aa.pdf

[2] “Practice Changes Reduce Coercive Psychiatric Measures,” Medscape, 11 Apr. 2024, https://www.medscape.com/viewarticle/practice-changes-reduce-coercive-psychiatric-measures-2024a10006z0?form=fpf

[3] https://psychnews.psychiatryonline.org/doi/full/10.1176/appi.pn.2016.3a10

[4] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p.  p. 13

[5] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p., p. 15

[6] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. p. 66

[7] https://www.cchrint.org/2023/09/18/who-guideline-condemns-coercive-psychiatric-practices/, citing “Study finds involuntary psychiatric detentions on the rise,” UCLA Newsroom, 3 Nov. 2020, https://newsroom.ucla.edu/releases/involuntary-psychiatric-detentions-on-the-rise

[8] https://www.cchrint.org/2023/09/18/who-guideline-condemns-coercive-psychiatric-practices/,  citing “Involuntary Commitments: Billing Patients for Forced Psychiatric Care,” The American Journ. of Psychiatry, 1 Dec. 2020, https://ajp.psychiatryonline.org/doi/10.1176/appi.ajp.2020.20030319

[9] https://rehabs.com/explore/mental-health-spending-by-state-across-the-us/

[10] David Robinson, “As NY pushes mental health plan, 13 hospitals use restraints above average. See which ones,” Democrat & Chronicle, 8 Feb. 2023, https://www.democratandchronicle.com/story/news/2023/02/07/new-york-state-psychiatric-patients-spent-hours-restraints-see-where/69871002007

[11] David Robinson, “As NY pushes mental health plan, 13 hospitals use restraints above average. See which ones,” Democrat & Chronicle, 8 Feb. 2023, https://www.democratandchronicle.com/story/news/2023/02/07/new-york-state-psychiatric-patients-spent-hours-restraints-see-where/69871002007

[12] Ruth Sangree, “I was hospitalized against my will. I know firsthand the harm it can cause,” The Guardian, 23 Dec. 2022, https://www.theguardian.com/society/2022/dec/23/involuntary-hospitalization-policy-new-york-city-eric-adams; https://health.wusf.usf.edu/npr-health/2018-09-13/the-crime-that-changed-mental-health-treatment

[13] https://nymag.com/intelligencer/2018/09/andrew-goldstein-release-kendras-law.html

[14] https://www.ascendantny.com/involuntary-treatment-laws-in-new-york/

[15] https://www.thehastingscenter.org/new-york-citys-involuntary-commitment-plan-fulfilling-a-moral-obligation/

[16] Jerry Iannelli, “Adams’ Forced Hospitalization Plan Will Have Lifelong Consequences,” The Appeal (independent journalism), 22 Dec. 2022, https://theappeal.org/nyc-mayor-eric-adams-involuntary-commitment/

[17] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p.  15

[18] Lauren Tenney, PhD, MPhil, MPA, Psychiatric Survivor “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist, MAD, 17 July, 2019, https://www.madinamerica.com/2019/07/kendras-law-racist-classist-involuntary/

[19] Lauren Tenney, Ph.D., “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist,” MAD, 17 July 2019, https://www.madinamerica.com/2019/07/kendras-law-racist-classist-involuntary/

[20] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 73

[21] https://www.cchrint.org/2021/01/26/american-psychiatric-associations-apology-for-harming-african-americans-rejected/; Megan Brooks, “APA Apologizes for Past Support of Racism in Psychiatry,” Medscape, 19 Jan 2019, https://www.medscape.com/viewarticle/944352?src=wnl_edit_tpal&uac=345404PY&impID=3143084&faf=1; APA’s Apology to Black, Indigenous and People of Color for Its Support of Structural Racism in Psychiatry, 18 Jan 2021,  https://www.psychiatry.org/news-room/apa-apology-for-its-support-of-structural-racism

[22] Ruth Sangree, “I was hospitalized against my will. I know firsthand the harm it can cause,” The Guardian, 23 Dec. 2022, https://www.theguardian.com/society/2022/dec/23/involuntary-hospitalization-policy-new-york-city-eric-adams

[23] Lauren Tenney, Ph.D., “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist,” MAD, 17 July 2019, https://www.madinamerica.com/2019/07/kendras-law-racist-classist-involuntary/

[24] Jerry Iannelli, “Adams’ Forced Hospitalization Plan Will Have Lifelong Consequences,” The Appeal (independent journalism), 22 Dec. 2022, https://theappeal.org/nyc-mayor-eric-adams-involuntary-commitment/

[25] Harvey Rosenthal, “Coercion and Institutionalization Won’t Fix NY’s Mental Health Crisis,”  City Limits, 30 Mar. 2022, https://citylimits.org/2022/03/30/opinion-coercion-and-institutionalization-wont-fix-nys-mental-health-crisis

[26] Lauren Tenney, Ph.D., “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist,” MAD, 17 July 2019, https://www.madinamerica.com/2019/07/kendras-law-racist-classist-involuntary/

[27] Lauren Tenney, Ph.D., “End Kendra’s Law Now: Racist, Classist Practices in Involuntary Psychiatry Persist,” MAD, 17 July 2019, https://www.madinamerica.com/2019/07/kendras-law-racist-classist-involuntary/

[28] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 15

[29] https://www.cchrint.org/2023/09/18/who-guideline-condemns-coercive-psychiatric-practices/

World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 58

[30] https://www.cchrint.org/2023/09/18/who-guideline-condemns-coercive-psychiatric-practices/

World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 55

[31] https://omh.ny.gov/omhweb/ect/guidance.html

[32] https://www.cchrint.org/2021/10/01/cchr-notifies-electroshock-hospitals-on-the-failure-to-inform-patients-of-risks/; “Neurological Devices; Reclassification of Electroconvulsive Therapy Devices; Effective Date of Requirement for Premarket Approval for Electroconvulsive Therapy Devices for Certain Specified Intended Uses,” U.S. Food and Drug Administration, Final Rule, 83 FR 66103, 26 Dec. 2018, https://www.federalregister.gov/documents/2018/12/26/2018-27809/neurological-devices-reclassification-of-electroconvulsive-therapy-devices-effective-date-of, § 882.5940, Electroconvulsive therapy device, (ix), (F)

[33] https://www.federalregister.gov/documents/2018/12/26/2018-27809/neurological-devices-reclassification-of-electroconvulsive-therapy-devices-effective-date-of

[34] http://www.jaapl.org/content/34/3/406.full.pdf

[35] https://www.cchrint.org/electroshock/, Richard C. Hermann, et al., “Variation in ECT Use in the United States,” The American Journal of Psychiatry, 152:6, Jun 1995, https://ajp.psychiatryonline.org/doi/epdf/10.1176/ajp.152.6.869

[36] http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3381633/

[37] https://www.cchrint.org/2023/09/18/who-guideline-condemns-coercive-psychiatric-practices/; World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 58

[38] World Health Organization, OHCHR, “Guidance on Mental Health, Human Rights and Legislation,” 9 Oct. 2023, p. 58

[39] https://truthaboutect.org/cchr-notifies-electroshock-hospitals-on-the-failure-to-inform-patients-of-risks/#_edn8; https://lifeafterect.com/how-to-report-your-ect-injury-to-the-fda/

[40] http://www.thymatron.com/catalog_cautions.asp

[41] https://truthaboutect.org/cchr-notifies-electroshock-hospitals-on-the-failure-to-inform-patients-of-risks/#_edn8

[42] https://omh.ny.gov/omhweb/ect/

[43] https://omh.ny.gov/omhweb/ect/

[44] https://www.brylin.com/center-of-excellence-electroconvulsive-therapy-treatment-ect-program/

[45] https://www.nyp.org/healthlibrary/other-details/electroconvulsive-therapy-ect

[46] https://nyulangone.org/conditions/depression/treatments/electroconvulsive-therapy-for-depression

[47] https://www.ynhh.org/psychiatric/services/specialized-services/electroconvulsive-therapy

[48] https://www.mountsinai.org/health-library/surgery/electroconvulsive-therapy

[49] https://www.cchrint.org/2022/10/14/an-open-letter-to-the-american-psychiatric-association-2/

[50] Peter Simons, “ECT Does Not Seem to Prevent Suicide,” Mad In America, 17 Feb. 2023, https://www.madinamerica.com/2023/02/ect-does-not-seem-to-prevent-suicide/

[51] https://www.cchrint.org/2023/02/07/legal-right-to-ban-electroshock-torture-device/; Matthew S. Smith & Michael Ashley Stein, “WHEN DOES MENTAL HEALTH COERCION CONSTITUTE TORTURE?: IMPLICATIONS OF UNPUBLISHED U.S. IMMIGRATION JUDGE DECISIONS DENYING NON-REFOULEMENT PROTECTION,” FORDHAM INTERNATIONAL LAW JOURNAL, Vol 45:5, 2022; pp. 797, 814, https://ir.lawnet.fordham.edu/ilj/vol45/iss5/2/

[52] https://www.psychiatry.org/psychiatrists/education/mental-health-innovation-zone