Heller v. Doe

United States Supreme Court

509 U.S. 312 (1993)

Under the Fourteenth Amendment’s Equal Protection Clause, states are permitted to require different levels of burden of proof for cases involving the involuntary commitment of the mentally ill versus the involuntary commitment of mentally retarded persons.

Relevant Facts

Kentucky law permits the involuntary commitment of mentally ill and mentally retarded persons. In order to do so, the state had the burden to prove that the person was dangerous, that treatment would be reasonably beneficial, and that there was no less restrictive alternative. The burden of proof to establish these three requirements for the mentally ill was “beyond a reasonable doubt.” The burden of proof for the mentally retarded, however, was “clear and convincing evidence,” which was a relatively lower standard of proof. The conflicting standards were challenged in the United States Supreme Court on equal protection grounds.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

Judicial Opinion

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Procedural History

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Citations

509 U.S. 312 (1993)