Addington v. Texas

Supreme Court of the United States · 1979 · Administrative Law

Civil commitmentDue ProcessStandard of proofFourteenth Amendmentcivil commitmentmental illnessdangerousnessclear and convincing evidence

Facts

Appellant had previously been temporarily committed multiple times and indefinitely committed to Austin State Hospital on three occasions. After his arrest on a misdemeanor charge of assault by threat against his mother, his mother filed a petition for his indefinite commitment under Texas law, and a county psychiatric examiner certified that he was mentally ill and required hospitalization. At trial, the State presented evidence of serious delusions, threats to injure his parents and others, assaultive episodes while hospitalized, and substantial property damage, and two psychiatrists opined that he suffered from psychotic schizophrenia with paranoid tendencies and was probably dangerous to himself and others. Appellant conceded that he suffered from mental illness but argued there was no substantial basis for concluding that he was probably dangerous.

Issue

What standard of proof the Fourteenth Amendment requires in a state-law civil proceeding to involuntarily commit an individual for an indefinite period to a state mental hospital. Specifically, the Court considered whether due process permits a preponderance standard or instead requires proof beyond a reasonable doubt.

Rule

In a civil proceeding to commit an individual involuntarily to a state mental hospital for an indefinite period, due process requires the State to prove the basis for commitment by evidence more substantial than a preponderance of the evidence. The Constitution does not require the criminal standard of proof beyond a reasonable doubt; a clear and convincing evidence standard is constitutionally sufficient, and states may choose an equal or greater burden.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Lila Moreno petitions to have her adult brother, Devin Moreno, involuntarily committed to a state psychiatric facility for an indefinite period. The statute allows commitment if the county proves mental illness and danger to self or others by a preponderance of the evidence.

If Devin argues that the statute violates due process solely because it permits commitment on a preponderance standard, what is the strongest response?

Explanation. Due process requires more than a mere preponderance of the evidence before a person may be involuntarily committed to a state mental hospital for an indefinite period. The individual's liberty interest and the adverse social consequences of commitment are too substantial to require the person to share equally with the State the risk of error.