## Facts

- Kentucky authorized involuntary civil commitment of (1) persons with mental illness and (2) persons with intellectual disabilities who were dangerous, could benefit from treatment, and for whom institutionalization was the least restrictive alternative.
- The two commitment tracks were largely similar but differed in two respects.
- For mental illness commitments, Kentucky required proof beyond a reasonable doubt; for intellectual disability commitments, Kentucky required clear and convincing evidence.
- In intellectual disability proceedings, guardians and immediate family members could participate “as if parties,” with full party rights; comparable participation was not provided in the same way for mental illness proceedings.
- A certified class of involuntarily committed persons with intellectual disabilities challenged these differences under the Fourteenth Amendment.
- The federal district court granted summary judgment to the class, enjoined enforcement of the challenged provisions, and the Sixth Circuit affirmed.
- The Supreme Court reviewed the 1990 version of the statutory framework and reversed.

## Issues

1. Whether different burdens of proof and different family/guardian participation rules for commitment of persons with intellectual disabilities versus persons with mental illness violate the Equal Protection Clause.
2. Whether granting guardians and immediate family members party-like participation in intellectual disability commitment proceedings violates the Due Process Clause.

## Decision

- The Supreme Court reversed the Sixth Circuit in a 5–4 decision authored by Justice Kennedy.
- Applying rational basis review, the Court held that the different burdens of proof did not violate equal protection.
- The Court held that allowing guardians and immediate family members to participate “as if parties” in intellectual disability proceedings did not violate equal protection.
- The Court held that the family/guardian participation rule did not violate due process given the overall procedural safeguards in the commitment process.
- The Court declined to consider an argument for heightened scrutiny because it was not preserved below.

## Legal Principles

- Under rational basis review, a statutory classification is valid if it bears a rational relationship to a legitimate governmental purpose; the State need not articulate the purpose at enactment or produce evidence to sustain rationality.
- Legislatures may draw imperfect lines; a “perfect fit” between means and ends is not required if plausible reasons support the classification.
- A State may calibrate procedural burdens of proof across related civil-commitment schemes based on differences such as comparative diagnostic certainty, to reduce the risk of erroneous determinations and protect public safety.
- Expanded participation rights for close family members and guardians in commitment proceedings may be constitutionally permissible where the State could reasonably view such participants as helpful sources of information and generally aligned with the individual’s welfare.
- Due process in civil commitment turns on the overall risk of erroneous deprivation in light of existing safeguards; participation by relatives or guardians is not unconstitutional where counsel, professional evaluations, and related protections remain in place.

## Conclusion

The Court upheld Kentucky’s distinct civil-commitment procedures for persons with intellectual disabilities, concluding that the different burden of proof and the family/guardian party-like participation rule were rationally related to legitimate state interests and did not create a due process violation.


Heller v. Doe, 509 U.S. 312 (1993)