Heller v. Doe Doe
| Citation | 125 L.Ed.2d 257,113 S.Ct. 2637,509 U.S. 312 |
| Decision Date | 24 June 1993 |
| Docket Number | No. 92-351,92-351 |
| Parties | Leonard HELLER, Secretary, Kentucky Cabinet for Human Resources, Petitioner v. Samuel DOE, By his Mother and Next Friend, Mary DOE, et al |
| Court | United States Supreme Court |
Kentucky permits the involuntary commitment of mentally retarded or mentally ill individuals who present a threat of danger to themselves, family, or others, who can reasonably benefit from the available treatment, and for whom the least restrictive alternative is placement in the relevant facility. However, the statutory procedures for the commitment of the two groups differ in the two respects at issue here. First, the applicable burden of proof in mental retardation commitment proceedings is clear and convincing evidence while the standard in mental illness proceedings is beyond a reasonable doubt. Second, guardians and immediate family members of the subject of a mental retardation proceeding may participate as if parties to those proceedings, with all attendant rights. In this action, respondents, a class of involuntarily committed mentally retarded persons, claimed that the distinctions are irrational and therefore violate the Fourteenth Amendment's Equal Protection Clause, and that granting close family members and guardians the status of parties violates the Due Process Clause. The District Court granted them summary judgment, and the Court of Appeals affirmed.
Held:
1. Respondents' claim that the statutes should be reviewed under a heightened scrutiny standard is not properly presented, since it was not raised below and the lower courts ruled only on the ground of rational-basis review. P. ____.
2. The distinctions between the two proceedings are consistent with the Equal Protection Clause. Pp. ____.
(a) Classifications neither involving fundamental rights nor proceeding along suspect lines do not run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and a legitimate governmental purpose. A legislature need not articulate its rationale, and a State need not produce evidence to sustain the classification's rationality. Moreover, courts are compelled to accept a legislature's generalization even when there is an imperfect fit between means and ends. Pp. ____.
(b) Kentucky has proffered more than adequate justifications for its burden of proof scheme. Mental retardation, which is a developmental disability usually well documented throughout childhood, is easier to diagnose than is mental illness, which may have a sudden onset in adulthood. Thus, it could have assigned a higher burden of proof to mental illness to equalize the risk of erroneous determination that the subject of a commitment proceeding has the condition in question. Ease of diagnosis could also result in a more accurate dangerousness determination for the mentally retarded, who have a relatively static condition and a well-documented record of previous behavior. In contrast, since manifestations of mental illness may be sudden, past behavior may not be an adequate predictor of future actions. A higher standard for the mentally ill is also justified on the ground that in general their treatment is much more intrusive than that received by the mentally retarded. Pp. ____.
(c) There is also a rational basis for Kentucky to allow immediate family members and guardians to participate as parties in proceedings to commit the mentally retarded but not the mentally ill. Kentucky could rationally conclude that close relatives and guardians may have intimate knowledge of the subject's abilities and experiences which provides valuable insights that should be considered during the involuntary commitment process. By contrast, mental illness may arise only after minority, when the afflicted person's immediate family members have ceased to provide care and support, and the proper course of treatment may depend on matters not related to observations made in a household setting. In addition, adults previously of sound mental health who are diagnosed as mentally ill may have a need for privacy that justifies confining a commitment proceeding to the smallest group possible. Whether Kentucky could have chosen a less-restrictive means than party status for achieving its legislative end is irrelevant in rational-basis review. Pp. ____.
3. Allowing close relatives and legal guardians to participate as parties does not violate due process. Consideration of the factors set out in Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18—the private interest that will be affected, the risk of an erroneous deprivation of such interest, and the government's interest compels this conclusion. Rather than increasing the risk of an erroneous deprivation, allowing close relatives and guardians to participate as parties actually increases a proceeding's accuracy by putting valuable information before the court. It also implements the State's interest in providing family members a voice in such proceedings. And even if they favor commitment, their participation does not undermine the interest of the individual facing commitment. The only individual interest that is protected by the Due Process Clause is in an accurate decision, not a favorable one. Pp. ____.
965 F.2d 109 (CA6 1992), reversed.
William K. Moore, Midway, KY, for petitioner.
Kelly Miller, Louisville, KY, for respondents.
In the Commonwealth of Kentucky, involuntary civil commitments of those alleged to be mentally retarded and of those alleged to be mentally ill are governed by separate statutory procedures. Two differences between these commitment proceedings are at issue in this case. First, at a final commitment hearing, the applicable burden of proof for involuntary commitment based on mental retardation is clear and convincing evidence, Ky.Rev.Stat.Ann. § 202B.160(2) (Michie 1991), while the standard for involuntary commitment based on mental illness is beyond a reasonable doubt, § 202A.076(2). Second, in commitment proceedings for mental retardation, unlike for mental illness, "[g]uardians and immediate family members" of the subject of the proceedings "may participate . . . as if a party to the proceedings," with all attendant rights, including the right to present evidence and to appeal. § 202B.160(3). Respondents are a class of mentally retarded persons committed involuntarily to Kentucky institutions. They argue that these distinctions are irrational and violate the Equal Protection Clause of the Fourteenth Amendment. They claim also that granting close family members and guardians the status of parties violates the Due Process Clause. We reject these contentions and hold the Kentucky statutes constitutional.
This case has a long and complicated history. It began in 1982 when respondents filed suit against petitioner, the Kentucky Secretary of the Cabinet for Human Resources, claiming that Kentucky's failure to provide certain procedural protections before institutionalizing people on the basis of mental retardation violated the Constitution. Kentucky has amended its civil commitment statutes several times since 1982, with each new statute being attacked in court by respondents. As the previous incarnations of this lawsuit have little effect on the issues currently before this Court, we limit our discussion to the current round of the litigation. See Doe v. Cowherd, 770 F.Supp. 354, 355-356 (WD Ky.1991) ().
At issue here are elements of Kentucky's statutory procedures, enacted in 1990, for the involuntary commitment of the mentally retarded. In many respects the procedures governing commitment of the mentally retarded and the mentally ill are parallel. The statutes recognize a large class of persons who can petition for an individual's involuntary commitment, whether on grounds of mental retardation or mental illness. Ky.Rev.Stat.Ann. § 202B.100(3) (Michie 1991) (mental retardation); § 202A.051 (mental illness). Upon filing of the petition, the trial court must appoint counsel to represent the individual in question, unless he retains private counsel. § 202B.210 (mental retardation); § 202A.121 (mental illness). The trial court also must examine the person who filed the petition and, if there is probable cause to believe that the individual who is the subject of the petition should be involuntarily committed, the court must order his examination by two qualified professionals. §§ 202B.100(5), (6)(c) (mental retardation); §§ 202A.051(5), (6)(c) (mental illness). The subject of the proceeding has the right to retain a professional of his own choosing, who may "witness and participate in any examination" of him. § 202B.140 (mental retardation); § 202A.066 (mental illness). In cases of commitment for mental retardation, a professional retained by the subject's "parent or guardian" also must be permitted to witness and participate in any examination. § 202B.140.
If both qualified professionals certify that the individual meets the criteria for involuntary commitment, the trial court must conduct a preliminary hearing. § 202B.130 (mental retardation); § 202A.061 (mental illness). At the hearing, the court must receive as evidence the reports of these two professionals and any other professional retained under the statute. § 202B.160(1) (mental retardation); § 202A.076(1) (mental illness). The individual whose commitment is sought may testify and may call and cross-examine witnesses. § 202B.160(1) (mental...
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