Heller v. Doe Ex Rel. Doe

1993-06-24

Headline: Ruling upholds Kentucky’s different commitment rules for the mentally retarded and mentally ill, allowing relatives to join retarded commitment cases and keeping a lower proof standard for institutionalizing people labeled mentally retarded.

Holding: The Court held that Kentucky’s law allowing family members to act as parties in commitment proceedings for people labeled mentally retarded and using a lower proof standard is constitutional under ordinary review.

Real World Impact:

Keeps lower proof standard for commitment when mental retardation is alleged.
Allows family members and guardians to participate as parties in those proceedings.

Topics: involuntary commitment, mental disability, family involvement, state mental health rules

Summary

Background

This dispute involves Kentucky laws that treat people alleged to be mentally retarded differently from those alleged to be mentally ill. The differences at issue were twofold: a lower proof standard (clear and convincing evidence) for commitment when retardation is alleged versus a higher standard (beyond a reasonable doubt) when illness is alleged, and a rule letting guardians and immediate family participate as formal parties in retardation proceedings. Respondents challenged those distinctions as unconstitutional; lower courts sided with respondents before the case reached this Court.

Reasoning

The Court framed the main question as whether Kentucky’s distinctions lacked any rational justification. It declined to adopt heightened constitutional review because that argument was not pressed below and instead applied ordinary rational-basis review. The majority found several plausible state reasons: that retardation is generally easier to document, that past dangerous behavior of long-standing conditions can be a more reliable predictor, and that typical treatment for retardation emphasizes training (habilitation) rather than invasive psychiatric procedures. Applying Mathews v. Eldridge, the Court also held that allowing relatives and guardians to participate as parties does not violate procedural due process and can improve the accuracy of decisions.

Real world impact

The decision allows Kentucky to continue using its lower proof standard in retardation cases and permits family or guardians to act as formal participants in those proceedings. Because many States have separate laws for retardation and illness, the ruling is likely influential for similar state commitment systems. The Court did not decide whether a stricter level of constitutional review should apply in other contexts.

Dissents or concurrances

Justice Souter (joined by Blackmun and Stevens) dissented, arguing the distinctions lack any rational basis and would uphold the lower courts. Justice O'Connor agreed that the lower proof standard was irrational but would uphold family participation; Justice Blackmun joined Souter and urged heightened scrutiny for disability classifications.