Joyce Patricia Brown (September 7, 1947 – November 29, 2005), also known as Billie Boggs, was a homeless woman who was forcibly hospitalized in New York City in 1987. She was the first person hospitalized under a Mayor Ed Koch administration program which expanded the city's ability to forcibly commit homeless New Yorkers to psychiatric hospitals. Between 1987 and 1988, Brown worked with the New York Civil Liberties Union to challenge her hospitalization in a case which attracted significant media attention. During the ensuing trial, her lawyers argued that her behaviors were not in line with social expectations but did not rise to the level of posing a danger to herself or others. Brown took the stand, and her clarity while testifying became part of the public conversation. The trial ended in her favor, and while the city won on appeal, she was ultimately released after a subsequent case determined that the city could not forcibly medicate her. Following her release, she made several television appearances and spoke about homelessness at Harvard Law School, but came to avoid the press. Her case sparked national conversations about how best to care for people with mental illnesses.

The 1975 Supreme Court decision O'Connor v. Donaldson limited involuntary psychiatric hospitalization to those who posed a danger to themselves or others. Many states passed legislation following the ruling, including New York, which passed its Mental Hygiene Law in 1978, allowing involuntary hospitalization of people with mental illness if they were considered a danger to themselves or others. The case was one part of a larger trend of deinstitutionalization in the United States, which began in the late 1950s and resulted in the release of hundreds of thousands of people from psychiatric hospitals. These changes, along with inadequate social programs, housing policies, and broader economic conditions contributed to an increase in homelessness in parts of the United States.

In New York City, Mayor Ed Koch established Project HELP (Homeless Emergency Liaison Project) in 1982 to provide food, clothing, medical, and psychiatric services to homeless people in Manhattan. Sometimes staff would bring people to psychiatric hospitals but most were not admitted because they did not fit the legal requirements. Koch was frustrated that so many of the people his staff determined needed hospitalization were not being treated due to the typical interpretation of New York law, so he began exploring ways to interpret the legal language differently. He was advised that case law could support a reinterpretation of the Mental Hygiene Law's requirement that someone be a "danger to themselves or others" to include a consideration of whether people's behaviors, including self-neglect, might pose a danger to themselves or others in the future, even if there was no immediate danger. While considering these changes, Koch met with people who would be affected by this change, including Brown, who would later become one of the first people involuntarily committed due to Koch's reinterpretation. On October 28, 1987, Koch announced a new program for removing homeless people with mental illness from the streets for reasons including self-neglect and future harm, using his new legal interpretation, allocating a 28-bed unit at Bellevue Hospital to take care of newly admissible patients. Project HELP's psychiatrists could then direct police officers to take people to a hospital, although involuntary hospitalization remained contingent upon not just Project HELP's doctors but also an emergency room psychiatrist and a psychiatrist at the inpatient facility agreeing that the patient met the criteria.

The New York Civil Liberties Union (NYCLU, the New York affiliate of the American Civil Liberties Union) firmly opposed Koch's program, criticizing it as a violation of the civil rights of mentally ill and homeless people. They argued that the Koch program attempted to hide homeless people, rather than help them through housing assistance and mental health clinics. Following Koch's announcement, NYCLU volunteers distributed fliers to people living on the street detailing their rights and advising them to contact the organization if they were involuntarily committed.

Joyce Patricia Brown was born in 1947, to a working-class family in Elizabeth, New Jersey. She was the youngest of six children, with four sisters and one brother. She worked as a secretary after graduating from high school, including for the city of Elizabeth. She struggled with several forms of substance abuse, and became addicted to both heroin and cocaine in the years after graduating. She began to hear voices and act erratically, resulting in her dismissal from her secretary job, and was later convicted of possession of heroin. In 1982, she was charged with assaulting a police officer at Newark Penn Station. She lived with her parents until 1977 and with her sisters in the mid-1980s, moving between their houses as tensions arose. They eventually pooled their money to get her a place of her own instead, but she was soon living in a homeless shelter.

In 1985, after being ejected from a shelter in Newark, her sisters took her to East Orange General Hospital for a psychiatric evaluation. She was hospitalized for fifteen days, diagnosed with a form of psychosis likely caused by schizophrenia, and prescribed Thorazine, which she did not take. She lived on disability benefits, alternating between living in shelters and at one of her sisters' houses. In May 1986, after an argument with her sisters, she left home for Manhattan, and her family did not see her again until she appeared on the news years later.

Brown took up residence on an air vent near Second Avenue at 65th Street by a Swensen's Ice Cream shop. She spent about a year there, during which time she was approached by Project HELP workers but refused their aid. They began monitoring her in December 1986 following concerned reports from people in the community. They checked in regularly, and were concerned about her ability to take care of herself, especially given her inadequate clothing during the cold winter. She was taken to psychiatric hospitals at Project HELP's recommendation three times in 1986 and 1987, each time diagnosed with schizophrenia but released upon determination that she did not pose a danger to herself or others. She was known to people in the neighborhood for alleged behaviors like running into traffic, exposing herself to passersby, threatening and screaming at people (especially black men), tearing up and urinating on money she was given, and defecating on the sidewalk. Neighbors described having conversations with her which were frequently pleasant but could also quickly veer into aggression. On October 28, 1987, she became the first person involuntarily committed under Koch's newly relaxed requirements.

Brown was taken to Bellevue Hospital on the first day of Koch's program, where she gave false names she had used in the past, including "Ann Smith" and "Billie Boggs". The name Billie Boggs was based on Bill Boggs, a former local television talk show host in New York City whom Brown had developed an obsession for years beforehand, and it was that name which was widely published in news stories about her case. Doctors at Bellevue diagnosed her with paranoid schizophrenia and injected with the anti-psychotic drug Haldol and a tranquilizer, Ativan. The next day, Brown contacted the NYCLU; staff attorney Robert Levy and Executive Director Norman Siegel took Brown's case. From the start, the case generated extensive media attention. Brown's sisters, who had been looking for her since she left home, went to Bellevue after recognizing court sketches of her in the news. They spoke to the media, requesting anonymity, urging compassion for the families of homeless people and recommending that Brown be committed to a hospital.