[Page 1898]In 1979, the U.S. Supreme Court decided an important case to protect the rights of people with a mental health disorder. The case was Addington v. Texas, 441 U.S. 418 (1979). Addington made civil commitment more difficult by raising the standard of proof (sometimes called the burden of proof).

Frank Addington, an individual with schizophrenia, violent tendencies, and a lengthy history of a number of hospitalizations, threatened to assault his mother. She sought to have him civilly committed for an indefinite period of time. The relevant Texas law required the court to determine whether Addington was mentally ill, whether he must be hospitalized to protect his own welfare and that of others, and whether he was “mentally incompetent.” The legal issue involved which standard of ...