Addington v. Texas

PETITIONER: Frank O’Neal Addington
RESPONDENT: Texas
LOCATION: Galveston County Probate Court

DOCKET NO.: 77-5992
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: Supreme Court of Texas

CITATION: 441 US 418 (1979)
ARGUED: Nov 28, 1978
DECIDED: Apr 30, 1979
GRANTED: Apr 17, 1978

ADVOCATES:
James Hury - for the respondent
Joel I. Klein - for the American Psychiatric Ass'n, as amicus curiae, by special leave of Court
Martha Boston - for the petitioner

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

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”?

Media for Addington v. Texas

Audio Transcription for Oral Argument - November 28, 1978 in Addington v. Texas

Warren E. Burger:

We'll hear arguments first this morning in Addington against Texas.

Ms. Boston you may proceed whenever you are ready.

Martha Boston:

Mr. Chief Justice and May it please the court.

The appellant in this case is confined in Austin State Hospital as a result of an order of indefinite commitment.

The appellant came from a disturbed family and in December of 1975 following a family argument, he was taken to jail and minor criminal charges were filed against him.

Those charges were subsequently dismissed and in their place the state instituted indefinite commitment proceedings.

The commitment trial lasted for five days, during which time the jury heard conflicting testimony as to the need to commit the appellant.

The appellant urged that the standard of proof in his case should be beyond a reasonable doubt but the jury was instructed to make its finding on clear unequivocal and convincing evidence.

Warren E. Burger:

The appellant is an adult, isn't he?

Martha Boston:

Pardon me.

Warren E. Burger:

He is an adult, is he not?

Martha Boston:

He is.

He is approximately thirty one.

Warren E. Burger:

He has been in mental institutions on how many occasions before this?

Martha Boston:

The record isn't clear on exactly how many occasions.

There have been several, I believe.

Warren E. Burger:

Somewhere in the record it suggested that he has been in ten times in the last five years.

Martha Boston:

I believe it was something like eight or nine within the last five years.

The appellant had urged that "beyond a reasonable doubt" be required but that was overruled and the court instructed clear and convincing evidence or clear unequivocal and convincing evidence.

The jury found that he was to be committed for an indefinite period of time and the appellant filed his appeal in the intermediate state appellate court on the basis that proof beyond a reasonable doubt is required by the due process clause.

That court agreed with the appellant and reversed the order of commitment, but on appeal to the State Supreme Court, that Court found that a mere preponderance of the evidence was all that was necessary to indefinitely confine a person in a mental hospital.

That court therefore reversed the Court of Civil Appeals and affirmed the order of commitment from the Trial Court.

As a result of this order of commitment, the appellant has been confined behind the locked doors of Boston State Hospital for almost three years.

He can't leave the facility, his movements, his activities; his visitors within the hospital are all restricted subject to supervision by the staff.

He's been subjected to chemical therapy and to twenty-two electroshock treatments.

He faces very real possibility that he may never leave the walls of Austin State Hospital.

Warren E. Burger:

If we go back to the standard, what was required to be proved to bring about a commitment in the jury trial that you say lasted five days?

Martha Boston:

The substantive standard in Texas is two issues.

The first is that the person is mentally ill and second, that the person requires hospitalization for his own welfare and protection or for the protection of others.

It's possible under the statute; it is actually required under the statute to reach a third issue regarding mental incompetency, but the state failed to plead that, so it was not submitted to the jury.