Addington v. Texas
Encyclopedia
Addington v. Texas , , is a U.S. Supreme Court landmark case that set the standard for involuntary commitment
for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and convincing" evidence.
charge of "assault threat" against his mother, Addington's mother filed a petition with the court, in accordance with Texas law, requesting that Addington be indefinitely involuntarily committed
to a state psychiatric hospital
. Addington had a long history of mental and emotional problems and past psychiatric hospitalizations. The state trial court issued jury instructions
that the decision be based on "clear, unequivocal and convincing evidence" that Addington was mentally ill and that hospitalization was required for his own welfare and the welfare of others. The jury found that Addington was mentally ill and required hospitalization. Thereupon the trial court ordered his indefinite commitment. He was indefinitely committed to Austin State Hospital
.
However, Addington appealed to the Texas Court of Appeals, based on the argument the court should have used the "beyond a reasonable doubt" standard of proof. The appeals court reversed, agreeing with Addington. The Texas Supreme Court
then reversed the Court of Appeals' decision, reinstating the trial court's orders. It concluded that the standard of proof of the preponderance of the evidence satisfied due process
in a civil commitment proceeding.
Addington then appealed to the U.S. Supreme Court on a writ
of certiorari
.
" in criminal cases, but should be a "clear and convincing" standard of proof as required by the Fourteenth Amendment
in such a civil proceeding to commit an individual involuntarily for an indefinite period to a state psychiatric hospital.
Further, the opinion touched on the issue of an involuntary commitment as primarily medical in nature and needing the expertise of mental health experts.
The opinion also suggested that it was not necessarily for the trier of facts to draw the necessary conclusions without the expertise of psychiatrists and psychologists.
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and convincing" evidence.
Circumstances
Before Frank Addington was arrested on the misdemeanorMisdemeanor
A misdemeanor is a "lesser" criminal act in many common law legal systems. Misdemeanors are generally punished much less severely than felonies, but theoretically more so than administrative infractions and regulatory offences...
charge of "assault threat" against his mother, Addington's mother filed a petition with the court, in accordance with Texas law, requesting that Addington be indefinitely involuntarily committed
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
to a state psychiatric hospital
Psychiatric hospital
Psychiatric hospitals, also known as mental hospitals, are hospitals specializing in the treatment of serious mental disorders. Psychiatric hospitals vary widely in their size and grading. Some hospitals may specialise only in short-term or outpatient therapy for low-risk patients...
. Addington had a long history of mental and emotional problems and past psychiatric hospitalizations. The state trial court issued jury instructions
Jury instructions
Jury instructions are the set of legal rules that jurors should follow when the jury is deciding a civil or criminal case. Jury instructions are given to the jury by the jury instructor, who usually reads them aloud to the jury...
that the decision be based on "clear, unequivocal and convincing evidence" that Addington was mentally ill and that hospitalization was required for his own welfare and the welfare of others. The jury found that Addington was mentally ill and required hospitalization. Thereupon the trial court ordered his indefinite commitment. He was indefinitely committed to Austin State Hospital
Austin State Hospital
Austin State Hospital , formerly known as the State Lunatic Asylum, is the oldest psychiatric hospital in the state of Texas, operated by the Texas Department of State Health Services. Established by the Legislature in 1856, it commenced operations in 1861 with twelve patients. The name was...
.
However, Addington appealed to the Texas Court of Appeals, based on the argument the court should have used the "beyond a reasonable doubt" standard of proof. The appeals court reversed, agreeing with Addington. The Texas Supreme Court
Texas Supreme Court
The Supreme Court of Texas is the court of last resort for non-criminal matters in the state of Texas. A different court, the Texas Court of Criminal Appeals, is the court of last resort for criminal matters.The Court is composed of a Chief Justice and eight Associate Justices...
then reversed the Court of Appeals' decision, reinstating the trial court's orders. It concluded that the standard of proof of the preponderance of the evidence satisfied due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
in a civil commitment proceeding.
Addington then appealed to the U.S. Supreme Court on a writ
Writ
In common law, a writ is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court...
of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Decision
The appeal was dismissed and certiorari granted; the lower court's decision was vacated and remanded. The court said the issue of an individual's interest in liberty is of such weight and gravity that a higher standard of proof is required than is normal in civil cases brought under state law. Because of the uncertainties of psychiatric diagnosis, the burden of proof does not need to be as high as "beyond a reasonable doubtBeyond a Reasonable Doubt
Beyond a Reasonable Doubt is a 1956 film directed by Fritz Lang and written by Douglas Morrow. The film, considered film noir, was the last American film directed by Lang.-Plot:...
" in criminal cases, but should be a "clear and convincing" standard of proof as required by the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
in such a civil proceeding to commit an individual involuntarily for an indefinite period to a state psychiatric hospital.
Further, the opinion touched on the issue of an involuntary commitment as primarily medical in nature and needing the expertise of mental health experts.
Significance
The court raised the bar for committing someone against their will in a civil commitment proceeding. When the stakes are exceptionally high in civil matters, the burden of proof must be "clear and convincing" evidence. The case raised important issues regarding civil commitment by placing the burden of proof on the petitioner, that is the party seeking the involuntary commitment of a person.The opinion also suggested that it was not necessarily for the trier of facts to draw the necessary conclusions without the expertise of psychiatrists and psychologists.
See also
- List of United States Supreme Court cases, volume 441
- Jones v. United States (1983)Jones v. United States (1983)Jones v. United States, is a United States Supreme Court case in which the court, for the first time, addressed whether the United States Constitution allows a defendant, who has been found not guilty by reason of insanity of a misdemeanor crime, to be involuntarily confined to a mental...
- Foucha v. LouisianaFoucha v. LouisianaFoucha v. Louisiana, 504 U.S. 71 , was a U.S. Supreme Court case in which the court addressed the criteria for the continued commitment of an individual who had been found not guilty by reason of insanity...