Addington v. Texas (1978)
- Docket
- 77-5992
- Decided
- 1978-01-01
Summary
Question: Is the proper standard of proof for a civil case of involuntary commitment to a mental health facility whether the evidence presented to the jury was “clear, unequivocal, and convincing”? Conclusion: The standard of proof in a civil confinement case requires a burden of proof higher than a preponderance of the evidence, but not as high as the “beyond a reasonable doubt” standard used in criminal cases. Chief Justice Warren E. Burger wrote the opinion for the unanimous Court, which held that the use of the “clear, unequivocal, and convincing” evidence standard in a jury instruction in a civil commitment case was proper. Because of the importance of the “beyond a reasonable doubt” standard set forth in criminal proceedings, the Court was weary of requiring the same standard for civil proceedings. Furthermore, this case involved psychiatric evaluation, which was not considered reliable evidence. A “beyond a reasonable doubt” requirement in cases involving mental diagnosis may be too high a burden for the state to reach. Therefore, the middle ground of requiring a “clear and convincing” standard of proof was appropriate. Justice Lewis F. Powell, Jr. took no part in the consideration or or decision of the case.