Addington v. Texas

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Addington v. Texas
U.S. LEXIS 93
Case history
PriorCert. to the Supreme Court of Texas
Holding
That a "clear and convincing" standard of proof is required by the Fourteenth Amendment in a civil proceeding brought under state law to commit an individual involuntarily for an indefinite period to a state mental hospital.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinion
MajorityBurger, joined by Brennan, Stewart, White, Marshall, Blackmun, Rehnquist, Stevens
Powell took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. XIV

Addington v. Texas, 441 U.S. 418 (1979), was a

clear and convincing evidence".[1]

Background

Before Frank Addington was arrested on the

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.[2]

However, Addington appealed to the

Addington then appealed to the U.S. Supreme Court on a writ of certiorari.

Opinion of the Court

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 "

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.[4]

Further, the opinion touched on the issue of an involuntary commitment as primarily medical in nature and needing the expertise of mental health experts.

Whether the individual is mentally ill and dangerous to either himself or others and is in need of confined therapy turns on the meaning of the facts which must be interpreted by expert psychiatrists and psychologists.[5]

Subsequent developments

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".[6] 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.[2]

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.[7]

The Supreme Court also cited the Addington case in Santosky v. Kramer, which set a clear and convincing evidence standard in termination of parental rights cases.

See also

Footnotes

  1. S2CID 23334418
    .
  2. ^ .
  3. ^ "Addington v. Texas No. 77-5992". supreme.justia.com. 1979. Retrieved January 22, 2008.
  4. ^ "Addington v. Texas". Oklahoma State Courts Network. Retrieved January 23, 2008.
  5. ^ "Addington v. Texas, 441 U.S. 418 (1979) - Full opinion". supreme.justia.com. Retrieved January 25, 2008.
  6. . Retrieved January 22, 2008.
  7. .

External links