State v. Addington

This case involves the proper standard of proof that is required in indefinite commitment cases under the provisions of the Texas Mental Health Code. 1 Frank Addington was committed to the Austin State Hospital for an indefinite period of time after the jury found that he was mentally ill and required hospitalization for his own welfare and protection, as well as for the protection of others. The trial judge instructed the jury that the State’s burden was to prove each special issue by “clear and convincing evidence.” The court of civil appeals reversed and held that the proper standard of…