Addington v. Texas

Infobox SCOTUS case
Litigants=Addington v. Texas
ArgueDate=November 28
ArgueYear=1978
DecideDate=April 30
DecideYear=1979
FullName=Frank O'Neal ADDINGTON v. State of TEXAS
USVol=441
USPage=418
Citation=Page 441 U. S. 419
Prior=Certiorari to the Texas Supreme Court
Subsequent=
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.
SCOTUS=1975-1981
Majority=Burger
JoinMajority=Rehnquist, Stewart, White, Blackmun, Marshall, Stevens, Brennan
Concurrence/Dissent=
Dissent=
Dissent2=
JoinDissent2=
LawsApplied=Fourteenth Amendment to the United States Constitution

Addington v. Texas , ussc|441|418|1979, is a U.S. Supreme Court landmark case that set the standard for involuntary commitment for treatment by raising the burden of proof required to commit persons from the usual civil burden of proof of "preponderance of the evidence" to "clear and convincing" evidence. [cite web
author=Hays, Jr.
year=1989
month=December
url=http://www.ncbi.nlm.nih.gov/sites/entrez?db=pubmed&uid=2623112&cmd=showdetailview&indexed=google
title=The role of Addington v Texas on involuntary civil commitment.|publisher=
accessdate=2008-01-22]

Circumstances

Before Frank Addington was arrested on the misdemeanor 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. Addington had a long history of mental and emotional problems and past psychiatric hospitalizations.cite web
author=Robert G. Meyer & Christopher M. Weaver
year=2005
url=http://books.google.com/books?id=_zU4PCsY774C&pg=PA135&lpg=PA135&dq=addington+v+texas&source=web&ots=hW7ePfifEK&sig=hHYJjtD_YOEwhNIO27n5SDq-zuk&hl=en
title=Law and Mental Health: A Case-Based Approach
publisher=Guilford Press
pages=p. 135
ISBN=1593852215
accessdate=2008-01-22] The state trial court issued jury instructions 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.

However, Addington appealed to the Texas Court of Appeals, based on the argument that the standard of proof used for his indefinite commitment was too low. The appeals court reversed, agreeing with Addington. The Texas Supreme Court then reversed the Court of Appeals' decision, reinstating the trial court's orders. It concluded that the standard of proof of the preponderance of the evidence satisfied due process in a civil commitment proceeding. [cite web
author=
year=1979
url=http://supreme.justia.com/us/441/418/
title=Addington v. Texas No. 77-5992
publisher=supreme.justia.com
accessdate=2008-01-22]

Addington then appealed to the U.S. Supreme Court on a writ of certiorari.

Decision

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" 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. [cite web
author=
year=
url=http://www.oscn.net/applications/oscn/deliverdocument.asp?citeid=430790
title=Addington v. Texas
publisher=Oklahoma State Courts Network
accessdate=2008-01-23]

Further, the opinion touched on the issue of an involuntary commitment as primarily medical in nature and needing the expertise of mental health experts.quotation|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. [cite web
author=
year=
url=http://supreme.justia.com/us/441/418/case.html
title=Addington v. Texas, 441 U.S. 418 (1979) - Full opinion
publisher=supreme.justia.com
accessdate=2008-01-25]

ignificance

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 "clear and convincing" evidence. [cite web
author=Jeffrey A. Helewitz
year=2000
url=http://books.google.com/books?id=gWJ38Lh_MaoC&pg=PA20&lpg=PA20&dq=addington+v+texas&source=web&ots=U3GuIMqPVh&sig=aMmNDo1HP9qJKaH4bQ5dbwGeeOg#PPA20,M1
title=Elder Law
publisher=CENGAGE Delmar Learning
pages=20
ISBN= 978-0766813717
accessdate=2008-01-22] 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.cite book
first=Gary
last=Melton
year= 1997
title= Psychological Evaluations for the Courts: A Handbook for Mental Health Professionals and Lawyers
edition= 2nd
publisher=The Guilford Press
location=New York
pages=p 304
id= ISBN 1-57230-236-4]

ee also

*List of United States Supreme Court cases, volume 441
*"Jones v. United States (1983)"
*"Foucha v. Louisiana"

Footnotes

External links

*caselaw source
case="Addington v. Texas", 441 U.S. 418 (1979)
enfacto=http://www.enfacto.com/case/U.S./441/418/
justia=http://supreme.justia.com/us/441/418/case.html
* [http://forensicpsychiatry.stanford.edu/Files/Landmark%20Case%20Summaries.pdf Landmark Case Summaries]
* [http://biotech.law.lsu.edu/cphl/articles/hastings/hastings-1_-3.htm Public Health Law Articles]