Addington v. Texas (1979): Case Brief, Summary & Ruling

Instructor: Natalie Boyd

Natalie is a teacher and holds an MA in English Education and is in progress on her PhD in psychology.

How much evidence must be presented in order for a person to lose his or her freedom? That question was at the heart of the 1979 SCOTUS case ''Addington v. Texas.'' In this lesson, we'll take a look at the case and the issues surrounding it.

Evidence

You've probably seen television shows where the jury is instructed that they can only convict if the evidence presented is ''beyond a reasonable doubt.'' But that's not the only standard of evidence in the court system. In fact, in many civil trials, the evidence doesn't have to rise to the reasonable doubt level. It just has to be a ''preponderance of the evidence.''

What does this mean? Well, imagine that you believe that your neighbor stole the flamingo from your front lawn. You decide to sue your neighbor to get enough money to replace the missing flamingo. Because your lawsuit is a civil and not a criminal case, you only have to present enough evidence to outweigh any evidence or arguments that your neighbor presents.

Think of it like this: if your evidence is put on a scale, it only has to weigh more than your neighbor's evidence. That's far less stringent a standard than ''beyond a reasonable doubt.''

But what about a civil case where a person's freedom is at stake? While this happens only in a few circumstances, it does happen. When a person's freedom is being taken away, how much evidence is necessary? That question was at the heart of the landmark 1979 Supreme Court case Addington v. Texas.

Case

It all started when Frank Addington's mother filed a petition with the court system in Texas to have him involuntarily committed to a psychiatric facility. In the subsequent trial, evidence was presented that showed that Addington had a long history with mental health issues.

This type of trial is considered a civil trial, because the defendant (Addington) wasn't on trial for committing a crime. Instead, the court was trying to decide if Addington was mentally unstable enough for the court to force him into a psychiatric institution.

The judge instructed the jury to decide if Addington was mentally unwell and if he should be involuntarily committed. He told the jury that they needed to decide these things based on whether the evidence presented was ''clear, unequivocal, and convincing.'' The jury found that the evidence was those three things, and Addington was committed to a psychiatric facility for an indefinite amount of time.

Appeals

Addington appealed the court's decision. His argument was simple. The Fourteenth Amendment guarantees due process before a person's freedom is taken away. Addington's lawyers argued that, as part of due process, his freedom can only be taken away with evidence that is ''beyond a reasonable doubt.'' Anything less, they argued, was a violation of the Fourteenth Amendment.

After a couple of rounds of appeals, the Texas State Supreme Court said that involuntary commitments to psychiatric facilities are part of civil court and therefore they only require a ''preponderance of the evidence.'' Remember this is a very low standard for evidence, and the Texas Supreme Court said that it was lower than the standard set at his trial of ''clear, unequivocal, and convincing evidence,'' his commitment should stand.

SCOTUS Decision

Addington again appealed, this time to the Supreme Court of the United States (sometimes abbreviated SCOTUS). His lawyers asked SCOTUS to rule that the Fourteenth Amendment insures that a person's freedom can only be taken away with the ''beyond a reasonable doubt'' standard.

SCOTUS disagreed with both Addington and the Texas Supreme Court. The unanimous decision (with one abstention) found that ''beyond a reasonable doubt'' did not apply to civil cases, including involuntary commitment cases. However, they also found that the due process clause of the Fourteenth Amendment meant that the ''preponderance of the evidence'' was not a stringent enough standard by which to take away a person's freedom.

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