In Parham v. J.R., 442 U.S. 584, 61 L. Ed. 2d 101, 99 S. Ct. 2493 (1979), the United States Supreme Court explored the nature and extent of a child's rights when the child is committed to a state mental hospital. 442 U.S. at 606-07. The United States Supreme Court stated that "it is not disputed that a child, in common with adults, has a substantial liberty interest in not being confined unnecessarily for medical treatment and that the state's involvement in the commitment decision constitutes state action under the Fourteenth Amendment." Parham, 442 U.S. at 600. Accordingly, the Court "assumed that a child has a protectible interest not only in being free of unnecessary bodily restraints but also in not being labeled erroneously by some persons because of an improper decision by the state hospital superintendent." Id. at 601. Under the Georgia statute challenged in Parham, a parent or guardian could admit a child for "observation and diagnosis." Id. at 591. The statute, governing voluntary admissions, further provided that if the superintendent of the hospital found "evidence of mental illness" and that the child was "suitable for treatment" in the hospital, the child could be admitted "for such period and under such conditions as may be authorized by law." Id. at 590-91. Although one of the plaintiffs in Parham had been voluntarily admitted to the mental hospital by his parents, the named plaintiff, J.R., was "declared a neglected child" and removed from his parents' care by the county. As a ward of the State of Georgia, J.R. had been admitted to the mental institution by the Georgia Department of Family and Children Services. See id. The Supreme Court first discussed whether the procedure used by the State of Georgia violated due process when the child's parent admitted the child to the state mental hospital. See Parham, 442 U.S. at 589-617. the Court determined that our precedents permit the parents to retain a substantial, if not the dominant, role in the decision, absent a finding of neglect or abuse, and that the traditional presumption that the parents act in the best interests of their child should apply. We also conclude, however, that the child's rights and the nature of the commitment decision are such that parents cannot always have absolute and unreviewable discretion to decide whether to have a child institutionalized. They, of course, retain plenary authority to seek such care for their children, subject to a physician's independent examination and medical judgment. Id. at 604.