Heller v. Doe

Kentucky law allowed involuntary commitment of mentally ill and 'mentally retarded' persons on proof of dangerousness, benefit of treatment, and no less-restrictive alternative. The standard of proof was 'beyond a reasonable doubt' for the mentally ill but the lower 'clear and convincing evidence' for the mentally retarded. The differing standards were challenged on equal-protection grounds.

Whether a state may constitutionally impose a lower burden of proof for the involuntary commitment of the mentally retarded than for the mentally ill under the Equal Protection Clause.