The October 1978 term of the United States Supreme Court was a watershed for prevention jurisprudence. In the companion cases of Addington v. Texas[141] and Bell v. Wolfish,[142] the Court rejected the rule of Winship and Gault that civil involuntary confinements require the same due process as criminal prosecutions. Both Addington and Bell recognize that the state may detain persons without punishing them.

[141] 441 U.S. 418 (1979).

[142] 441 U.S. 520 (1979).