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Notre Dame J.L. Ethics & Pub. Pol'y.


When the lives of Kendra Webdale and Andrew Goldstein crossed paths in a New York City subway on January 3, 1999, no one could have predicted the tragic results of their brief encounter, nor the political and legal aftermath the events of that day would spur. According to eyewitnesses, Goldstein, a twenty-nine year old man with a long history of psychiatric illness,' approached Webdale, a thirty-two year old woman, to ask her the time as she waited for an uptown train. Goldstein then suddenly and- inexplicably pushed Webdale in front of the approaching train; she died instantly. 2 Public outrage followed Webdale's death when the press discovered that Goldstein, a diagnosed schizophrenic, had not been taking his anti-psychotic medications at the time he committed this horrific crime.3 After several other highly publicized incidents in New York City involving violent outbursts by homeless, mentally ill individuals,4 public support grew for a bill introduced in the New York Legislature known as "Kendra's Bill."5 Kendra's Bill proposed an outpatient commitment program that would require individuals with a history of mental illness to take anti-psychotic medication or face involuntary civil commitment.6 Kendra's Bill was passed by the New York Senate on August 9, 1999 and signed into law by New York Governor George Pataki on August 27, 1999. 7 The bill then became known as "Kendra's Law.