Joyce Patricia Brown (perhaps better known as Billie Boggs) was a homeless person who defeated New York City's efforts to force her into a psychiatric treatment program. Her case set legal precedents for forced psychiatric care which have hamstrung involuntary psychiatric commitments of the homeless in New York and elsewhere. During Brown's 1987-1988 commitment and trial, Dr. , a Columbia University assistant professor of psychiatry, testified that Brown was mentally ill. The Social Security Death Index reports that Brown died on November 29, 2005.