Addington v. Texas
ADDINGTON v. TEXAS
SUPREME COURT OF THE UNITED STATES
441 U.S. 418; 99 S. Ct. 1804; 60 L. Ed. 2d 323; 1979 U.S.
November 28, 1978, Argued
April 30, 1979, Decided
APPEAL FROM THE SUPREME COURT OF TEXAS.
DISPOSITION: Appeal dismissed and certiorari granted; 557 S. W. 2d 511, vacated and remanded.
DECISION: “Clear and convincing” standard of proof in state involuntary commitment proceeding, held to be required by Fourteenth Amendment due process.
SUMMARY: After all evidence had been presented in a Texas trial court with respect to a petition for the indefinite commitment of an individual in accordance with Texas law, the trial court submitted the case to the jury, instructing it to find whether on “clear, unequivocal and convincing” evidence the individual was mentally ill and required hospitalization in a mental hospital for his own welfare and protection or the protection of others. The jury found in the affirmative on both questions, and the trial court entered an order committing the individual as a patient to a state hospital for an indefinite period. The individual appealed to the Court of Civil Appeals of Texas arguing, among other things, that any standard of proof less than “beyond a reasonable doubt” violated his procedural due process rights. The Court of Civil Appeals of Texas agreed and reversed the trial court’s judgment (546 SW2d 105). On appeal, the Supreme Court of Texas reversed, reaffirming one of its prior decisions in which it had been ruled that a “preponderance of the evidence” standard of proof in a civil commitment proceeding satisfied due process, and holding that the trial court’s use of a stricter standard was harmless error (557 SW2d 511).
On appeal, the United States Supreme Court, concluding that no appeal was authorized and dismissing the appeal, but construing the papers filed as a petition for certiorari and granting certiorari, vacated and remanded. In an opinion by Burger, Ch. J., expressing the unanimous view of the eight participating members of the court, it was held that the due process guarantees of the Fourteenth Amendment require a “clear and convincing” standard of proof in a state involuntary commitment proceeding, a mere preponderance of the evidence standard not being sufficient, and a state not being required to apply the strict, criminal standard of “beyond a reasonable doubt” or to use the term “unequivocal” in conjunction with the terms “clear and convincing.”
Powell, J., did not participate.
CONSTITUTIONAL LAW §830(1)
INCOMPETENT PERSONS §2
due process — civil commitment — necessary standard of proof –