In the case of Cole, Boston State Hospital Superintendent, et al. v. Richardson in 1969, the U.S Supreme Court was tasked with determining whether a state hospital could involuntarily commit an individual without providing them with legal counsel during commitment proceedings. The appellant in this case was a patient at Boston State Hospital who had been committed against his will and without representation by an attorney during his commitment hearing. He argued that this violated his constitutional rights to due process under the Fourteenth Amendment. The court ruled unanimously in favor of Richardson, stating that involuntary civil commitments are subject to due process protections under the Constitution which includes right to counsel for individuals facing such proceedings. This decision set a precedent for future cases involving involuntary commitments and affirmed that these individuals have certain constitutional rights including access to legal representation.

In the dissenting opinion for Cole, Boston State Hospital Superintendent, et al. v. Richardson (1969), Justice Harlan disagreed with the majority's decision that a state hospital could not involuntarily commit an individual without providing them with legal counsel during commitment proceedings. He argued that due process does not always require representation by counsel in civil cases and suggested that other safeguards such as judicial review of commitment decisions might be sufficient to protect individuals' rights. Furthermore, he expressed concern about the potential burden on states if they were required to provide attorneys for all persons facing involuntary commitment.