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Heller v. Doe | 509 U.S. 312 (1993)
The Fourteenth Amendment’s Equal Protection Clause prohibits states from treating some persons differently from others without sufficient justification. In Heller versus Doe, we explore what constitutes sufficient justification.
Kentucky law allowed for the involuntary commitment of adults with mental illness and cognitive impairment, at the time referred to as mental retardation. The commitment process was generally the same for both. It required the state to prove that a person was either mentally ill or cognitively impaired, that they posed a threat to themselves or others, that they would benefit from residential treatment, and that residential treatment was the least restrictive treatment available.
But the statutes treated the mentally ill and cognitively impaired differently in two ways. First, for mental-illness commitments, the burden of proof was beyond a reasonable doubt. But for cognitive-impairment commitments, it was the lesser burden of clear and convincing evidence. Second, in hearings regarding cognitive impairment, but not mental illness, guardians and immediate family members were entitled to participate as if they were parties.
A class of cognitively impaired persons sued Leonard Heller, a Kentucky official. They argued, among other things, that there was no rational basis for the state’s disparate treatment, and it therefore violated the Equal Protection Clause.
The district court granted summary judgment in the class’s favor, and the Sixth Circuit affirmed. The United States Supreme Court granted cert.
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