Addington v. Texas
Addington v. Texas | |
---|---|
Case history | |
Prior | Cert. 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 | |
| |
Case opinion | |
Majority | Burger, 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
Background
Before Frank Addington was arrested on the
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 "
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 "
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
- Jackson v. Indiana (1972)
- O'Connor v. Donaldson (1975)
- Jones v. United States (1983)
- Foucha v. Louisiana (1992)
Footnotes
- S2CID 23334418.
- ^ ISBN 978-1-59385-221-4.
- ^ "Addington v. Texas No. 77-5992". supreme.justia.com. 1979. Retrieved January 22, 2008.
- ^ "Addington v. Texas". Oklahoma State Courts Network. Retrieved January 23, 2008.
- ^ "Addington v. Texas, 441 U.S. 418 (1979) - Full opinion". supreme.justia.com. Retrieved January 25, 2008.
- ISBN 978-0-7668-1371-7. Retrieved January 22, 2008.
- ISBN 978-1-57230-236-5.
External links
- Text of Addington v. Texas, 441 U.S. 418 (1979) is available from: Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)
- Landmark Case Summaries
- Public Health Law Articles