Heller v. Doe
Annotate this Case
509 U.S. 312 (1993)
OCTOBER TERM, 1992
HELLER, SECRETARY, KENTUCKY CABINET FOR HUMAN RESOURCES v. DOE, BY HIS MOTHER AND NEXT FRIEND, DOE, ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
No.92-351. Argued March 22, 1993-Decided June 24,1993
Kentucky permits the involuntary commitment of mentally retarded or mentally ill individuals who present a threat of danger to themselves, family, or others, who can reasonably benefit from the available treatment, and for whom the least restrictive alternative is placement in the relevant facility. However, the statutory procedures for the commitment of the two groups differ in the two respects at issue here. First, the applicable burden of proof in mental retardation commitment proceedings is clear and convincing evidence while the standard in mental illness proceedings is beyond a reasonable doubt. Second, guardians and immediate family members of the subject of a mental retardation proceeding may participate as if parties to those proceedings, with all attendant rights. In this action, respondents, a class of involuntarily committed mentally retarded persons, claimed that the distinctions are irrational and therefore violate the Fourteenth Amendment's Equal Protection Clause, and that granting close family members and guardians the status of parties violates the Due Process Clause. The District Court granted them summary judgment, and the Court of Appeals affirmed.
1. Respondents' claim that the statutes should be reviewed under a heightened scrutiny standard is not properly presented, since it was not raised below and the lower courts ruled only on the ground of rationalbasis review. Pp. 318-319.
2. The distinctions between the two proceedings are consistent with the Equal Protection Clause. Pp. 319-330.
(a) Classifications neither involving fundamental rights nor proceeding along suspect lines do not run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and a legitimate governmental purpose. A legislature need not articulate its rationale, and a State need not produce evidence to sustain the classification's rationality. Moreover, courts are compelled to accept a legislature's generalization even when there is an imperfect fit between means and ends. Pp.319-321.
(b) Kentucky has proffered more than adequate justifications for its burden of proof scheme. Mental retardation, which is a developmental disability usually well documented throughout childhood, is easier to diagnose than is mental illness, which may have a sudden onset in adulthood. Thus, it could have assigned a higher burden of proof to mental illness to equalize the risk of erroneous determination that the subject of a commitment proceeding has the condition in question. Ease of diagnosis could also result in a more accurate dangerousness determination for the mentally retarded, who have a relatively static condition and a well-documented record of previous behavior. In contrast, since manifestations of mental illness may be sudden, past behavior may not be an adequate predictor of future actions. A higher standard for the mentally ill is also justified on the ground that, in general, their treatment is much more intrusive than that received by the mentally retarded. Pp.321-328.
(c) There is also a rational basis for Kentucky to allow immediate family members and guardians to participate as parties in proceedings to commit the mentally retarded but not the mentally ill. Kentucky could rationally conclude that close relatives and guardians may have intimate knowledge of the subject's abilities and experiences which provides valuable insights that should be considered during the involuntary commitment process. By contrast, mental illness may arise only after minority, when the afflicted person's immediate family members have ceased to provide care and support, and the proper course of treatment may depend on matters not related to observations made in a household setting. In addition, adults previously of sound mental health who are diagnosed as mentally ill may have a need for privacy that justifies confining a commitment proceeding to the smallest group possible. Whether Kentucky could have chosen a less-restrictive means than party status for achieving its legislative end is irrelevant in rationalbasis review. Pp. 328-330.
3. Allowing close relatives and legal guardians to participate as parties does not violate due process. Consideration of the factors set out in Mathews v. Eldridge, 424 U. S. 319, 335-the private interest that will be affected, the risk of an erroneous deprivation of such interest, and the government's interest-compels this conclusion. Rather than increasing the risk of an erroneous deprivation, allowing close relatives and guardians to participate as parties actually increases a proceeding's accuracy by putting valuable information before the court. It also implements the State's interest in providing family members a voice in such proceedings. And even if they favor commitment, their participation does not undermine the interest of the individual facing commitment. The only individual interest that is protected by the