Addington v. Texas Case Brief

Facts of the Case

Frank Addington was charged with “assault by threat” of his mother. His mother then filed a petition for his permanent confinement in a mental health facility. At trial, evidence was presented that Addington suffered from serious delusions, and two physicians testified that he was a psychotic schizophrenic. The jury was instructed to decide Addington’s mental state and whether he was a possible threat to himself and others by weighing the “clear, unequivocal and convincing evidence.” The jury determined the evidence was sufficient, and Addington was sentenced to Austin State Hospital for an indefinite amount of time. He appealed on the grounds that the jury should have been instructed to evaluate the evidence using the “beyond a reasonable doubt” standard. The state appellate court remanded his case stating that his rights had been violated when the jury was improperly instructed on the burden of proof. The Supreme Court of Texas overturned the appellate court’s decision and reinstated the trial court’s finding by holding that the standard of proof used in the initial jury instructions was adequate for a civil proceeding and did not violate Addington’s due process rights.

Question

“Did the Secretary of Commerce’s decision to apportion overseas personnel of the Department of Defense to their “homes of record” for census purposes meet the constitutional requirement of a census counting the number of people “in each State,” or was the procedure “arbitrary and capricious” under the Administrative Procedure Act?”

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.”

Case Information

Citation: 441 US 418 (1979)
Argued: Nov 28, 1978
Decided: Apr 30, 1979
Granted: Apr 17, 1978
Case Brief: 1979