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

landmark decision Landmark court decisions, in present-day common law legal systems, establish precedents that determine a significant new legal principle or concept, or otherwise substantially affect the interpretation of existing law. "Leading case" is commonly u ...

of the

US Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point of ...

that set the standard for

involuntary commitment Involuntary commitment, civil commitment, or involuntary hospitalization/hospitalisation is a legal process through which an individual who is deemed by a qualified agent to have symptoms of severe mental disorder is detained in a psychiatric hos ...

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 In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...

" to "

clear and convincing evidence In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...

Background

Before Frank Addington was arrested on the

misdemeanor A misdemeanor (American English, spelled misdemeanour elsewhere) is any "lesser" criminal act in some common law legal systems. Misdemeanors are generally punished less severely than more serious felonies, but theoretically more so than adm ...

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 Psychiatric hospitals, also known as mental health hospitals, behavioral health hospitals, are hospitals or wards specializing in the treatment of severe mental disorders, such as schizophrenia, bipolar disorder, eating disorders, dissociative ...

. Addington had a long history of mental and emotional problems and past psychiatric hospitalizations. The state trial court issued

jury instructions Jury instructions, directions to the jury, or judge's charge are legal rules that jurors should follow when deciding a case. They are a type of jury control procedure to support a fair trial. Description Jury instructions are the set of legal ...

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 (ASH), formerly known until 1925 as the Texas State Lunatic Asylum, is a 299-bed psychiatric hospital located in Austin, Texas. It is the oldest psychiatric facility in the state of Texas, and the oldest continuously operating ...

. However, Addington appealed to the

Texas Court of Appeals The Texas Courts of Appeals are part of the Texas judicial system. In Texas, all cases appealed from district and county courts, criminal and civil, go to one of the fourteen intermediate courts of appeals, with one exception: death penalty cases. ...

, based on the argument the court should have used the "beyond a reasonable doubt"

standard of proof In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...

. The appeals court reversed, agreeing with Addington. The

Texas Supreme Court The Supreme Court of Texas (SCOTX) is the supreme court, court of last resort for civil matters (including juvenile delinquency cases, which are categorized as civil under the Texas Family Code) in the U.S. state of Texas. A different court, the ...

then reversed the Court of Appeals' decision, reinstating the trial court's orders. It concluded that the standard of proof of the

satisfied

due process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual pers ...

in a

civil commitment Involuntary commitment, civil commitment, or involuntary hospitalization/hospitalisation is a legal process through which an individual who is deemed by a qualified agent to have symptoms of severe mental disorder is detained in a psychiatric hos ...

proceeding. Addington then appealed to the U.S. Supreme Court on a

writ In common law, a writ (Anglo-Saxon ''gewrit'', Latin ''breve'') is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court. Warrants, prerogative writs, subpoenas, a ...

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...

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 "

beyond a reasonable doubt Beyond a reasonable doubt is a legal standard of proof required to validate a criminal conviction in most adversarial legal systems. It is a higher standard of proof than the balance of probabilities standard commonly used in civil cases, beca ...

" 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.

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 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. 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.

Footnotes

External links

* {{caselaw source , case=''Addington v. Texas'', {{Ussc, 441, 418, 1979, el=no , findlaw=https://caselaw.findlaw.com/us-supreme-court/441/418.html , googlescholar = https://scholar.google.com/scholar_case?case=1383560548954406906 , justia=https://supreme.justia.com/cases/federal/us/441/418/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep441/usrep441418/usrep441418.pdf , oyez =https://www.oyez.org/cases/1978/77-5992
Landmark Case Summaries

United States Supreme Court cases United States Supreme Court cases of the Burger Court United States civil commitment case law Mental health case law in the United States 1979 in United States case law

Background

Opinion of the Court

Subsequent developments

See also

Footnotes

External links