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

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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.

Held: 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 rational-basis 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.

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