441 U.S. 418 (1979), 77-5992, Addington v. Texas
|Docket Nº:||No. 77-5992|
|Citation:||441 U.S. 418, 99 S.Ct. 1804, 60 L.Ed.2d 323|
|Party Name:||Addington v. Texas|
|Case Date:||April 30, 1979|
|Court:||United States Supreme Court|
Argued November 28, 1978
APPEAL FROM THE SUPREME COURT OF TEXAS
Appellant's mother filed a petition for his indefinite commitment to a state mental hospital in accordance with Texas law governing involuntary commitments. Appellant had a long history of confinements for mental and emotional disorders. The state trial court instructed the jury to determine whether, based on "clear, unequivocal and convincing evidence," appellant was mentally ill and required hospitalization for his own welfare and protection or the protection of others. Appellant contended that the trial court should have employed the "beyond a reasonable doubt" standard of proof. The jury found that appellant was mentally ill and that he required hospitalization, and the trial court ordered his commitment for an indefinite period. The Texas Court of Appeals reversed, agreeing with appellant on the standard of proof issue. The Texas Supreme Court reversed the Court of Appeals' decision and reinstated the trial court's judgment, concluding that a "preponderance of the evidence" standard of proof in a civil commitment proceeding satisfied due process, and that, since the trial court's improper instructions in the instant case had benefited appellant, the error was harmless.
Held: A "clear and convincing" standard of proof is required by the Fourteenth Amendment in a civil proceeding brought under state law to commit an individual involuntarily for an indefinite period to a state mental hospital. Pp. 425-433.
(a) The individual's liberty interest in the outcome of a civil commitment proceeding is of such weight and gravity, compared with the state's interests in providing care to its citizens who are unable, because of emotional disorders, to care for themselves and in protecting the community from the dangerous tendencies of some who are mentally ill, that due process requires the state to justify confinement by proof more substantial than a mere preponderance of the evidence. Pp. 425-427.
(b) Due process does not require states to use the "beyond a reasonable doubt" standard of proof applicable in criminal prosecutions and delinquency proceedings. In re Winship, 397 U.S. 358, distinguished. The reasonable doubt standard is inappropriate in civil commitment proceedings because, given the uncertainties of psychiatric diagnosis, it [99 S.Ct. 1806] may impose a burden the state cannot meet, and thereby erect an unreasonable barrier to needed medical treatment. The state should
not be required to employ a standard of proof that may completely undercut its efforts to further the legitimate interests of both the state and the patient that are served by civil commitments. Pp. 427 431.
(c) To meet due process demands in commitment,proceedings, the standard of proof has to inform the factfinder that the proof must be greater than the "preponderance of the evidence" standard applicable to other categories of civil cases. However, use of the term "unequivocal" in conjunction with the terms "clear and convincing" in jury instructions (as included in the instructions given by the Texas state court in this case) is not constitutionally required, although states are free to use that standard. Pp. 431-433.
Appeal dismissed and certiorari granted; 557 S.W.2d 511, vacated and remanded.
BURGER, C.J., delivered the opinion of the Court, in which all other Members joined, except POWELL, J., who took no part in the consideration or decision of the case.
BURGER, J., lead opinion
MR. CHIEF JUSTICE BURGER delivered the opinion of the Court.
The question in this case is what standard of proof is required by the Fourteenth Amendment to the Constitution in a civil proceeding brought under state law to commit an
individual involuntarily for an indefinite period to a state mental hospital.
On seven occasions between 1969 and 1975, appellant was committed temporarily, Tex.Rev.Civ.Stat.Ann., Arts. 5547-31 to 5547-39 (Vernon 1958 and Supp. 1978-1979), to various Texas state mental hospitals and was committed for indefinite periods, Arts. 5547-40 to 5547-57, to Austin State Hospital on three different occasions. On December 18, 1975, when appellant was arrested on a misdemeanor charge of "assault by threat" against his mother, the county and state mental health authorities therefore were well aware of his history of mental and emotional difficulties.
Appellant's mother filed a petition for his indefinite commitment in accordance with Texas law. The county psychiatric examiner interviewed appellant while in custody, and, after the interview, issued a Certificate of Medical Examination for Mental Illness. In the certificate, the examiner stated his opinion that appellant was "mentally ill and require[d] hospitalization in a mental hospital." Art. 5547 42 (Vernon 1958).
Appellant retained counsel, and a trial was held before a jury to determine, in accord with the statute:
(1) whether the proposed patient is mentally ill, and if so
(2) whether he requires hospitalization in a mental hospital for his own welfare and protection or the protection of others, and if so
(3) whether he is mentally incompetent.
Art. 5547-51 (Vernon 1958). The trial on these issues extended over six days.
The State offered evidence that appellant suffered from serious delusions, that he often had threatened to injure both of his parents and others, that he had been involved in several
assaultive episodes while hospitalized, and that he had caused substantial property damage both at his own apartment and at his parents' home. From these undisputed facts, two psychiatrists, who qualified as experts, expressed opinions that appellant suffered from psychotic schizophrenia and that he had paranoid tendencies. They also expressed medical opinions that appellant was probably dangerous both to himself and to others. They explained that appellant required hospitalization in a closed area to treat his condition because, in the past, he had refused to attend [99 S.Ct. 1807] outpatient treatment programs and had escaped several times from mental hospitals.
Appellant did not contest the factual assertions made by the State's witnesses; indeed, he conceded that he suffered from a mental illness. What appellant attempted to show was that there was no substantial basis for concluding that he was probably dangerous to himself or others.
The trial judge submitted the case to the jury with the instructions in the form of two questions:
1. Based on clear, unequivocal and convincing evidence, is Frank O'Neal Addington mentally ill?
2. Based on clear, unequivocal and convincing evidence, does Frank O'Neal Addington require hospitalization in a mental hospital for his own welfare and protection or the protection of others?
Appellant objected to these instructions on several grounds, including the trial court's refusal to employ the "beyond a reasonable doubt" standard of proof.
The jury found that appellant was mentally ill, and that he required hospitalization for his own or others' welfare. The trial court then entered an order committing appellant as a patient to Austin State Hospital for an indefinite period.
Appellant appealed that order to the Texas Court of Civil Appeals, arguing, among other things, that the standards for commitment violated his substantive due process rights, and that any standard of proof for commitment less than that
required for criminal convictions, i.e., beyond a reasonable doubt, violated his procedural due process rights. The Court of Civil Appeals agreed with appellant on the standard of proof issue, and reversed the judgment of the trial court. Because of its treatment of the standard of proof, that court did not consider any of the other issues raised in the appeal.
On appeal, the Texas Supreme Court reversed the Court of Civil Appeals' decision. 557 S.W.2d 511. In so holding, the Supreme Court relied primarily upon its previous decision in State v. Turner, 556 S.W.2d 563 (197...
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