Addington v. Texas

Background

A man with a long history of mental-health hospitalizations was arrested after an alleged assault by threat and his mother filed a petition under Texas law to have him committed indefinitely to a state hospital. A county psychiatric examiner issued a certificate saying he was mentally ill and needed hospitalization. At a six-day jury trial the State’s experts testified he suffered from psychotic schizophrenia and was probably dangerous; the jury was instructed using the words “clear, unequivocal and convincing evidence,” and it found him mentally ill and in need of hospitalization.

Reasoning

The Court addressed what level of proof the Fourteenth Amendment requires before a state can confine someone to a mental hospital indefinitely. It explained that a commitment is a serious loss of liberty and that a mere preponderance of the evidence risks inappropriate confinement. But the Court also found the criminal beyond-a-reasonable-doubt standard unsuitable because psychiatric diagnosis involves medical judgment and uncertainty. The Justices concluded that due process demands a higher burden than preponderance but not the criminal standard; a “clear and convincing” level satisfies constitutional minimums. The Court said the trial court’s “clear, unequivocal and convincing” instruction was constitutionally adequate and left precise state-law formulation to the Texas Supreme Court.

Real world impact

States must require more than a simple preponderance before ordering indefinite involuntary hospitalization, but they need not use criminal proof rules. The case was vacated and remanded for further proceedings consistent with this ruling.