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====Enclaves and new civil liberties==== The decade from 1965 to 1975 saw an expansion of civil liberties. Administratively, the ACLU responded by appointing [[Aryeh Neier]] to take over from Pemberton as executive director in 1970. Neier embarked on an ambitious program to expand the ACLU; he created the ACLU Foundation to raise funds and created several new programs to focus the ACLU's legal efforts. By 1974, ACLU membership had reached 275,000.<ref>Walker, pp. 314β16.</ref> During those years, the ACLU worked to expand legal rights in three directions: new rights for persons within government-run "enclaves", new rights for members of what it called "victim groups", and privacy rights for citizens in general.<ref>Walker, p. 299. Key ACLU leaders in this effort were [[Ira Glasser]] and [[Aryeh Neier]].</ref> At the same time, the organization grew substantially. The ACLU helped develop the field of constitutional law that governs "enclaves", which are groups of persons that live in conditions under government control. Enclaves include mental hospital patients, military members, prisoners, and students (while at school). The term enclave originated with Supreme Court justice [[Abe Fortas]]'s use of the phrase "schools may not be enclaves of totalitarianism" in the ''[[Tinker v. Des Moines]]'' decision.<ref>Raskin, James B. (2009), "No Enclaves of Totalitarianism", American University Law Review, Vol. 58:1193.</ref> The ACLU initiated the legal field of student's rights with the ''Tinker v. Des Moines'' case and expanded it with cases such as ''[[Goss v. Lopez]]'', which required schools to provide students an opportunity to appeal suspensions.<ref>Walker, p. 307.</ref> As early as 1945, the ACLU had taken a stand to protect the rights of the mentally ill when it drafted a model statute governing mental commitments.<ref name=W309>Walker, p. 309.</ref> In the 1960s, the ACLU opposed involuntary commitments unless it could be demonstrated that the person was a danger to himself or the community.<ref name=W309/> In the landmark 1975 ''[[O'Connor v. Donaldson]]'' decision, the ACLU represented a non-violent mental health patient who had been confined against his will for 15 years and persuaded the Supreme Court to rule such involuntary confinements illegal.<ref name=W309/> The ACLU has also defended the rights of mentally ill individuals who are not dangerous but create disturbances. The New York chapter of the ACLU defended [[Billie Boggs]], a woman with mental illness who exposed herself and defecated and urinated in public.<ref name="google">{{cite book|title=The Future Once Happened Here: New York, D.C., L.A., and the Fate of America's Big Cities|author=Siegel, F.|date=2013|publisher=Encounter Books|isbn=978-1594035555|url=https://books.google.com/books?id=0l73QSrSIcwC|page=205|access-date=October 3, 2014}}</ref> Before 1960, prisoners had virtually no recourse to the court system because courts considered prisoners to have no civil rights.<ref>Note, "Beyond the Ken of Courts", ''Yale Law Journal'' 72 (1963):506. Cited by Walker, p. 310.</ref> That changed in the late 1950s, when the ACLU began representing prisoners subject to [[police brutality]] or deprived of religious reading material.<ref name=W310>Walker, p. 310.</ref> In 1968, the ACLU successfully sued to desegregate the Alabama prison system; in 1969, the New York affiliate adopted a project to represent prisoners in New York prisons. Private attorney [[Phil Hirschkop]] discovered degrading conditions in Virginia prisons following the [[Virginia State Penitentiary strike]] and won an important victory in 1971's ''[[Landman v. Royster]]'' which prohibited Virginia from treating prisoners in inhumane ways.<ref>Walker, pp. 310β11. The ACLU was not involved in the ''Landman'' case.</ref> In 1972, the ACLU consolidated several prison rights efforts across the nation and created the [[National Prison Project]]. The ACLU's efforts led to landmark cases such as ''[[Ruiz v. Estelle]]'' (requiring reform of the Texas prison system), and in 1996 [[United States Congress|US Congress]] enacted the [[Prison Litigation Reform Act]] (PLRA) which codified prisoners' rights.
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