Science and Law: Addington v. Texas: When can mentally ill people be committed against their will?

September 14, 2016

Science and Law


441 U.S. 418 (1979)

The mentally ill are a controversial group in U.S. public health. Some believe they need to be committed to prevent them from harming themselves or others, but that also leads to the risk of erroneously committing people who do not require it, a serious infringement on individual liberty.

In this case, the courts had to consider what standard of evidence should be used to determine if a person should be committed. In this case, the appellant had a long history of short commitments to mental hospitals, and in the most recent case was arrested on charges of assault and threats against his own mother. This led the mother to file a petition for indefinite commitment. The Texas State Supreme Court upheld this petition based on “clear, unequivocal, and convincing evidence.”

In the appeal, the court was asked to reconsider the standard the court used to determine whether or not a person was mentally ill and could therefore be committed against his or her will.

What are the issues involved in the case?

The appellant’s side argued that the court should use the criminal law standard of proof – “beyond a reasonable doubt” to decide this case, a much higher standard than the Texas Supreme Court used in the earlier trial.

Let’s break down the two main different standards of proof:

“Beyond a reasonable doubt” vs. “A preponderance of evidence”

The former is around the 90%+ threshold and is used for criminal cases to determine guilt, whereas the latter is only  a 51% threshold and is used in civil cases to determine whether or not to award damages. A great example to show the difference between the two is the infamous O.J. Simpson case. People often forget that O.J. Simpson was involved in two cases – the criminal case and the civil case. While the prosecution failed to prove “beyond a reasonable doubt” that O.J. Simpson was guilty of murder, O.J. Simpson actually lost the wrongful death civil case, and the Brown and Goldman families were awarded compensatory and punitive damages totaling $33.5 million.

The important question is, why does the court use these different standards? An important difference is how the punishment may impact individual liberty. Monetary damages are unpleasant, but they do not physically restrict a person’s movement or infringe on other rights. Jail on the other hand, does constitute a severe restriction of liberty, meaning that the court must use stricter discretion when making this type of judgment.

The appellant argued that civil commitment was similar to prison in terms of how it infringed on individual liberty, and so the court should use this standard to meet the due process requirement.

How did the court interpret the law and rule?

The court recognized that civil commitment and imprisonment both constitute a severe restriction of individual liberty, but emphasized a key difference that undermined the appellant’s argument.

Guilt in criminal cases can and should rely on the higher standard because the evidence used in proceedings is provable and concrete, generally speaking, making it entirely possible to meet the “beyond reasonable doubt” threshold. Furthermore, these cases discuss events that have already transpired, as opposed to possible future behavior.

Whether or not a person has mental illness and is a threat to themselves or others is much more subjective, coming from professional psychiatric diagnosis. It is also requiring medical professionals to make predictions about a person’s potential harmful behavior in the future, as opposed to establishing guilt for past actions. Requiring the “beyond reasonable doubt” standard would actually interfere with the government’s interest in protecting the population from people with dangerous mental illness, and also deny people with mental illness much needed access to treatment.

The Court’s ruling and conclusion

The Texas State Supreme Court’s decision was vacated and remanded, meaning the Court sent the case back to the Texas State Supreme Court for more deliberations to clarify the standard necessary for civil commitment as a matter of state law. The court held that the standard should be higher than the preponderance threshold, but not as high as the beyond-reasonable-doubt threshold.

This case provides a useful explanation when and why different standards of evidence are used, and shows the delicate balance between protecting society from the mentally ill (and protecting the mentally ill from themselves) and respecting individual autonomy.

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About jslachman381

I'm a Yale graduate who majored in History of Science, Medicine, and Public Health.

View all posts by jslachman381


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One Comment on “Science and Law: Addington v. Texas: When can mentally ill people be committed against their will?”

  1. Richard Says:

    Excellent post. I was checking continuously this blog and I’m impressed! Very useful info particularly the last part



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