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Constitutional Law Keyed to Farber
Heller v. Doe
Citation:
509 U.S. 312, 113 S. Ct. 2637, 125 L. Ed. 2d 257 (1993)Facts
The Commonwealth of Kentucky maintained separate statutory procedures for involuntary civil commitment of mentally retarded and mentally ill individuals. For mental retardation commitments, Kentucky required proof by clear and convincing evidence of four elements: that the person is mentally retarded, presents danger to self or others, requires institutional placement as the least restrictive alternative, and can benefit from available treatment. For mental illness commitments, Kentucky required substantially identical elements proven beyond a reasonable doubt. Additionally, in mental retardation proceedings, guardians and immediate family members could participate as parties with full rights including presenting evidence, cross-examining witnesses, and appealing decisions, while mental illness proceedings did not grant such party status to family members. Respondents, a class of involuntarily committed mentally retarded persons, challenged these distinctions after Kentucky’s 1990 statutory amendments, arguing the differential treatment lacked rational basis and violated equal protection, and that family participation violated due process. The District Court and Court of Appeals agreed with respondents and invalidated the distinctions.
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