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Heller v. Doe

Supreme Court of the United States · 1993 · Constitutional Law
Constitutional LawEqual ProtectionInvoluntary CommitmentMental Disabilityincomplete excerptno majority text providedequal protectionmental retardation

Facts

The provided excerpt discusses Kentucky's different institutionalization procedures for persons alleged to be mentally retarded and persons alleged to be mentally ill. It focuses on two differences: the allocation of the risk of error through different burdens of proof and the participation of family members or guardians as parties in retardation commitment proceedings. The excerpt argues that both groups have a strong liberty interest and may be subjected to intrusive treatment, including psychotropic drugs and behavior-modification therapy. It also notes that relatives or guardians were involved in nearly all commitments to Kentucky's state-run institutions for the mentally retarded during a specified period.

Issue

The majority-opinion issue cannot be reliably stated from the provided text because no majority-opinion segment is included. The excerpt, which is not the majority's reasoning, discusses whether Kentucky may treat alleged mental retardation differently from alleged mental illness in civil commitment procedures consistent with equal protection.

Rule

No majority-opinion rule can be extracted from the provided segment. The excerpt contains a dissenting analysis that rejects the Court's conclusion and therefore cannot supply the controlling black-letter rule.

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Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.
A bar-prep company gives students an excerpt from a Supreme Court opinion discussing equal protection and civil commitment procedures. The excerpt repeatedly says "the Court" is wrong and ends with the author stating, "I would affirm" on grounds the statute is unconstitutional, but the majority opinion is not provided.

If a student is asked to identify the controlling doctrine of the case from that excerpt alone, which is the best answer?

Explanation. The controlling rule of a Supreme Court case must come from the majority or lead opinion. Here, the provided text explicitly disagrees with "the Court" and says "I would affirm," showing it is not the majority. Because no majority-opinion text is provided, no binding doctrine can be derived strictly from the materials. (Derived from Heller v. Doe (1993).)