In the case of Schmidt, Director of Wisconsin Department of Health and Social Services, et al. v. Lessard in 1973, the U.S Supreme Court addressed issues related to involuntary commitment for mental health treatment. The plaintiff, Lessard had been involuntarily committed to a state hospital on grounds that she was mentally ill and posed danger to herself or others. She challenged her confinement arguing that it violated her constitutional rights because there were less restrictive alternatives available for treatment and care outside institutional settings. The court ruled in favor of Lessard stating that before an individual can be involuntarily committed for indefinite periods based on mental illness diagnosis; three conditions must be met: clear evidence showing person is dangerous due to their mental illness; proof beyond reasonable doubt standard should apply rather than preponderance of evidence; and right to jury trial if requested by patient or guardian. This landmark decision significantly impacted laws regarding involuntary commitment across states as they were required to revise their statutes accordingly ensuring more stringent protections against unjustified deprivation of liberty.

In the dissenting opinion for Schmidt v. Lessard, it was argued that the majority's decision to require a finding of dangerousness before involuntary commitment could occur would place an undue burden on state mental health systems and potentially endanger both individuals suffering from mental illness and society at large. The dissenting justices believed that states should have more discretion in determining their own standards for involuntary commitment, as they are better positioned to assess local needs and resources. They also expressed concern about potential due process violations resulting from the new requirement, arguing that it might lead to arbitrary or discriminatory enforcement practices. Finally, they suggested that requiring proof of dangerousness may discourage early intervention efforts aimed at preventing harm rather than simply reacting to it.