Addington v. Texas (1979)
In Addington v. Texas (1979) 441 U.S. 418, a mentally ill defendant arrested for a misdemeanor assault was indefinitely committed to a mental hospital after a jury found by "clear, unequivocal and convincing evidence" that he required hospitalization for his own welfare and the protection of others. (Addington, supra, 441 U.S. at p. 421.)
On appeal, the defendant argued that the only standard of proof that satisfied due process in a civil commitment proceeding was proof beyond a reasonable doubt. The Texas Supreme Court concluded that proof by a preponderance of the evidence was sufficient. The United States Supreme Court reversed the Texas Supreme Court, finding that the "preponderance of the evidence" standard was too low to comport with due process, given the liberty interest at stake. (Id. at p. 433.)
However, the Court also rejected the argument that the only standard of proof that satisfies due process in civil commitment proceedings is proof "beyond a reasonable doubt." (Id. at p. 430.)
On this point the Court observed:
"The heavy standard applied in criminal cases manifests our concern that the risk of error to the individual must be minimized even at the risk that some who are guilty might go free. The full force of that idea does not apply to a civil commitment. It may be true that an erroneous commitment is sometimes as undesirable as an erroneous conviction However, even though an erroneous confinement should be avoided in the first instance, the layers of professional review and observation of the patient's condition, and the concern of family and friends generally will provide continuous opportunities for an erroneous commitment to be corrected." (Id. at pp. 428-429.)
The Court held that the middle level burden of proof by clear and convincing evidence struck "a fair balance between the rights of the individual and the legitimate concerns of the state" and satisfied due process. (Id. at p. 431.)
The United States Supreme Court decided what standard of proof was required under the due process clause of the Fourteenth Amendment in an involuntary commitment proceeding. The court weighed the individual's interest in not being committed involuntarily and indefinitely in a state mental hospital against the state's interest in confining those who are emotionally disturbed and dangerous. Addington, supra, 441 U.S. at page 425.
On the one hand, the individual has a significant liberty interest in being free from confinement and free from the stigma associated with such confinement. Addington, supra, 441 U.S. at pages 425-426.
On the other hand, the state, under its parens patriae power, has a legitimate interest in providing treatment for the mentally ill, and also, under its police power, has a legitimate interest in protecting the community from dangerous individuals. Addington, supra, 441 U.S. at page 426.
In weighing these countervailing interests, the Supreme Court considered the risk of erroneous decisions. Reasoning that the preponderance of the evidence standard allowed for a greater risk of error in making involuntary commitment decisions, the court held that the protection of the liberty interest at stake required a higher standard of proof.
The court, however, rejected the argument that civil commitment proceedings required the standard of proof reserved for criminal cases. "This unique standard of proof, not prescribed or defined in the Constitution, is regarded as a critical part of the 'moral force of the criminal law,' , and we should hesitate to apply it too broadly or casually in noncriminal cases. " Based on certain considerations, including the civil nature of involuntary commitment proceedings and the treatment aspect of the mentally ill person's confinement, the court held that the federal Constitution does not require proof beyond a reasonable doubt. Instead, the court concluded that, in light of the individual and governmental interests involved, due process would be satisfied with the midlevel standard of clear and convincing evidence. Addington, supra, 441 U.S. at pages 431-433.The Supreme Court held that an "individual's interest in the outcome of a civil commitment proceeding is of such weight and gravity that due process requires the state to justify confinement by proof more substantial than a mere preponderance of the evidence." 441 U.S. at 427.
The Addington Court held that the "proof beyond a reasonable doubt" standard was not required in such proceedings "because, given the uncertainties of psychiatric diagnosis, it may impose a burden the state cannot meet and thereby erect an unreasonable barrier to needed medical treatment." Id. at 432. Instead, due process guarantees are satisfied as long as the standard of proof applied is at least equal to or greater than the clear and convincing standard. Id. at 431-33.