American Notes NEW YORK CITY

After her release from a mental hospital in January, Joyce Brown seemed to have a new start in life. As one of the first homeless people picked up in Mayor Ed Koch's program to take people suspected of being mentally ill off the street, Brown won a controversial test case when a judge ruled that she could not be forced to submit to treatment. The former "Billie Boggs," as she called herself, appeared on Donahue and lectured to Harvard Law School students on the plight of the homeless. She found housing in a somewhat seedy hotel in Times Square.

Last week, however, there were signs that Brown's newfound status had not cured her deeper problems. She was spotted back on the street, begging for money and shouting obscenities at passersby. The next day Brown claimed that she had needed cash for cigarettes and food. "I'm not insane," she insisted. It remains to be seen whether Brown has sacrificed her well-being by standing up for her rights.