Heller v. Doe

509 U.S. 312, 113 S. Ct. 2637 (1993)



Rational-basis review in equal protection analysis is not a license for courts to judge the wisdom, fairness, or logic of legislative choices. Nor does it authorize the judiciary to sit as a superlegislature to judge the wisdom or desirability of legislative policy determinations made in areas that neither affect fundamental rights nor proceed along suspect lines. A classification neither involving fundamental rights nor proceeding along suspect lines is accorded a strong presumption of validity. Such a classification cannot run afoul of the Equal Protection Clause, U.S. Const. amend. XIV, if there is a rational relationship between the disparity of treatment and some legitimate governmental purpose. A legislature that creates these categories need not actually articulate at any time the purpose or rationale supporting its classification. Instead, a classification must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification.


Respondents, involuntarily committed mentally retarded persons, argued that different standards were required for commitment of mentally retarded and mentally ill persons. Ky. Rev. Stat. Ann. § 202B.160(2) required clear and convincing evidence for commitment based on mental retardation. Ky. Rev. Stat. Ann. § 202A.076(2) required proof beyond a reasonable doubt for commitment based on mental illness. The Respondents alleged that Kentucky's statutes relating to the involuntary commitment of mentally retarded individuals were in violation of the Equal Protection Clause as to the standards of evidence applied and involvement of guardians and family members in the process. The district court and court of appeals agreed that this violated the Equal Protection Clause. The state appealed the case to the Supreme Court of the United States.


Were the Kentucky's statutes for the involuntary commitment of retarded persons in violation of the Equal Protection Clause?




The Court found that separate standards were required because of the differing nature of individuals in each category. The Court stated that mental retardation existed from birth while mental illness could appear at any time. The Court applied a rational-basis review of the statutes. Under that standard, the burden was on the party attacking the statutes and the State was not required to produce evidence to show the rationality of its statutory classifications. The Court also held that the involvement of guardians and family members did not violate due process because those persons normally had valuable information to assist a factfinder in determining whether commitment was required.

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