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In a later decision, Zinermon v. Burch, 494 U.S. 113, 110 S. Ct. 975, 108 L. Ed. 2d 100 (1990), the Court further addressed dangerousness as a justification for civil commitment. It stated that involuntary commitment procedures "guard against the confinement of a person who, though mentally ill, is harmless and can live safely outside an institution." Confinement of such a person would be unconstitutional, the Court held.
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