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Addington v. Texas - 441 U.S. 418, 99 S. Ct. 1804 (1979)

Rule:

The Supreme Court of the United States repeatedly has recognized that civil commitment for any purpose constitutes a significant deprivation of liberty that requires due process protection.

Facts:

Addington's mother filed a petition for his indefinite commitment to a state mental hospital in accordance with Texas law governing involuntary commitments. Addington had a long history of confinements for mental and emotional disorders. The state trial court instructed the jury to determine whether Addington was mentally ill and required hospitalization for his own welfare and protection or the protection of others based on "clear, unequivocal and convincing evidence." Addington contended that the trial court should have employed the "beyond a reasonable doubt" standard of proof. The jury found that Addington was mentally ill and that he required hospitalization; the trial court ordered his commitment for an indefinite period. On appeal, a Texas appellate court reversed, agreeing with Addington on the standard-of-proof issue. The Texas Supreme Court reversed the appellate court's 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 Addington, the error was harmless.

Issue:

Was due process satisfied by the "preponderance of evidence" standard of proof in a civil commitment proceeding?

Answer:

No.

Conclusion:

The Supreme Court of the United States held that "preponderance of the evidence" standard was not sufficient as the standard of proof in a civil commitment proceeding. The Court found that because civil commitment was a significant deprivation of liberty that required due process protection, the state was required to justify confinement by proof more substantial than a mere preponderance of the evidence. Because a civil commitment proceeding was not comparable to a criminal prosecution, the Court refused to apply the beyond a reasonable doubt standard of proof because it would be unlikely that the state could ever meet such a burden because of the fallibility and lack of certainty of psychiatric diagnoses. Applying a middle level of burden of proof, the Court vacated the commitment order and remanded for a determination of whether the proof of Addington's mental illness and dangerousness to himself and others was proven by more than a preponderance of the evidence.

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