Detention Of S. J., 54860-7

S.J. had been civilly committed to Western State Hospital (initial 90 days) and faced a petition for a 180‑day extension for grave disability under former RCW 71.05.
The commitment hearing was before a superior court commissioner; hospital psychologist Dr. Debra Burnison testified S.J. has schizoaffective disorder (bipolar type), psychotic symptoms, mood lability, tangential/delusional thinking, verbal aggression, and impaired volitional control.
Dr. Burnison relied on examination, records, and staff reports, and testified S.J. had ~30 community hospitalizations, multiple prior Western State admissions, a history of stopping medication, and would likely fail to obtain essential care if released.
S.J. testified she had funds, disability income, housing plans, and would continue medications; she disputed staff testimony and denied stopping meds in the past.
The commissioner entered written findings and ordered 180 days of involuntary treatment; the superior court judge denied S.J.’s motion to revise (adopting the commissioner’s decision), and S.J. appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate review may consider the commissioner’s factual findings (adequacy of findings for review)	S.J.: Review should be limited to the superior court judge’s order, which contained no detailed findings, making review impossible	State: Commissioner’s findings become the superior court’s when the judge denies revision; those findings are properly before the court	The court held the commissioner’s findings were adopted by the superior court and are available for appellate review; findings were sufficiently specific
Whether the evidence met the clear, cogent, and convincing standard to prove grave disability under former RCW 71.05.020(22)(b)	S.J.: The State only showed hospitalization might be beneficial, not the required recent, significant loss of cognitive/volitional control or inability to obtain essential care	State: Dr. Burnison’s testimony and S.J.’s treatment history (numerous hospitalizations, stopping meds, current symptoms) showed decompensation and a likely failure to receive essential care if released	The court held the findings were supported by substantial evidence meeting the clear, cogent, and convincing standard and supported a conclusion of grave disability

In re the Det. of Thomas LaBelle, 107 Wn.2d 196 (Wash. 1986) (defines "gravely disabled," decompensation concept, and requires specific findings)
Maldonado v. Maldonado, 197 Wn. App. 779 (Wash. Ct. App. 2017) (commissioner’s order becomes the superior court’s when the judge declines revision)
In the Matter of the Det. of L.K., 14 Wn. App. 2d 542 (Wash. Ct. App. 2020) (standard for superior court review of commissioner’s decision on revision)
In re Det. of M.K., 168 Wn. App. 621 (Wash. Ct. App. 2012) (appellate review limited to whether substantial evidence supports the findings)
In the Matter of Det. of T.C., 11 Wn. App. 2d 51 (Wash. Ct. App. 2019) (defines substantial evidence as a quantum sufficient to persuade a fair‑minded person)