Leonard Heller, Secretary, Kentucky Cabinet for Human Resources v. Samuel Doe, BY His Mother and Next Friend, Mary Doe, et al. (509 U.S. 312)
U.S. Supreme Court · decided June 24, 1993 · Supreme Court Database (Spaeth)
- Citation
- 509 U.S. 312 · 113 S. Ct. 2637
- Decided
- June 24, 1993
- Term
- October Term 1992
- Vote
- 5–4
- Majority author
- Justice Kennedy
- Issue area
- Due Process
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Kennedy delivered the opinion of the Court. In the Commonwealth of Kentucky, involuntary civil commitments of those alleged to be mentally retarded and of those alleged to be mentally ill are governed by separate statutory procedures. Two differences between these commitment proceedings are at issue in this case. First, at a final commitment hearing, the applicable burden of proof for involuntary commitment based on mental retardation is clear and convincing evidence, Ky. Rev. Stat. Ann. §202B. 160(2) (Michie 1991), while the standard for involuntary commitment based on mental illness is beyond a reasonable doubt, § 202A.076(2). Second, in commitment proceedings for mental retardation, unlike for mental illness, “[g]uardians and immediate family members” of the subject of the proceedings “may participate ... as if a party to the proceedings,” with all attendant rights, including the right to present evidence and to appeal. § 202B. 160(3). Respondents are a class of mentally retarded persons committed involuntarily to Kentucky institutions. They argue that these distinctions are irrational and violate the Equal Protection Clause of the Fourteenth Amendment. They claim also that granting close family members and guardians the status of parties violates the Due Process Clause. We reject these contentions and hold the Kentucky statutes constitutional. I This case has a…
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