Addington v. Texas

441 U.S. 418 (1979)

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Facts

On seven occasions between 1969 and 1975, D was committed temporarily to various Texas state mental hospitals and was committed for indefinite periods, to Austin State Hospital on three different occasions. On December 18, 1975, when D was arrested on a misdemeanor charge of 'assault by threat' against his mother, the county and state mental health authorities therefore were well aware of his history of mental and emotional difficulties. D's mother filed a petition for his indefinite commitment in accordance with Texas law. An examiner stated his opinion that D was 'mentally ill and [required] hospitalization in a mental hospital.' A trial was held before a jury. P offered evidence that D suffered from serious delusions, that he often had threatened to injure both of his parents and others, that he had been involved in several assaultive episodes while hospitalized, and that he had caused substantial property damage both at his own apartment and at his parents' home. Two psychiatrists, who qualified as experts, expressed opinions that D suffered from psychotic schizophrenia and that he had paranoid tendencies. They also expressed medical opinions that D was probably dangerous both to himself and to others. They explained that D required hospitalization in a closed area to treat his condition because in the past he had refused to attend outpatient treatment programs and had escaped several times from mental hospitals. D conceded that he suffered from a mental illness. D claimed there was no substantial basis for concluding that he was probably dangerous to himself or others. The trial judge submitted the case on the basis of clear, unequivocal, and convincing evidence, that D is mentally ill, and based on that same evidence and standard should D be hospitalized in a mental hospital for his own welfare and protection or the protection of others. D claimed the standard should be beyond a reasonable doubt. The jury found that D was mentally ill and that he required hospitalization for his own or others' welfare. D appealed. The Court of Appeals agreed that the standard of proof should be beyond a reasonable doubt and reversed the judgment. The Texas Supreme Court reversed holding that a 'preponderance of the evidence' standard of proof in a civil commitment proceeding satisfied due process. It concluded that the trial court's instruction to the jury, although not in conformity with the legal requirements, had benefited D, and hence the error was harmless. Accordingly, the court reinstated the judgment of the trial court. D appealed.

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