in Re Commitment of J.S.T., 01-15-00075-CV

J.T. was diagnosed with active pulmonary tuberculosis (cavitary lesion on chest x-ray) and prescribed multi‑month treatment but repeatedly failed to complete it.
Harris County initially treated J.T.; he received only short courses and disappeared multiple times before being reencountered by Galveston County Health District (GCHD).
GCHD restarted treatment, warned him that failure to comply could lead to protective‑custody proceedings, and later filed for temporary protective custody and an order for extended management under Tex. Health & Safety Code ch. 81.
At trial (Jan 12–13, 2015) the jury found unanimously for commitment; evidence showed 4 of 7 close contacts tested positive and experts testified J.T. could transmit TB and that treatment lapses risk drug‑resistant TB.
The trial court ordered J.T. to participate remotely by two‑way video after the Health Authority advised he must remain isolated and that in‑person presence posed a public‑health risk; defense counsel did not object at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved elements for an order of extended management (infection, danger to self or public, >90 days) by clear and convincing evidence	J.T. contends evidence was insufficient to show he was likely to harm himself or endanger public health	State: diagnosis undisputed; cavitary TB harms patient; treatment noncompliance and positive contacts support public‑health danger and risk of drug‑resistant TB	Court: State met clear‑and‑convincing standard on all required elements (infectious TB, risk of harm to self and public, >90 days)
Whether requiring the patient to attend trial solely by video teleconferencing violated statutory or due process rights	J.T. argued lack of proper notice/technology and that remote participation infringed due process	State: §81.169 permits remote appearance when health authority advises isolation/quarantine risk; court followed statutory procedure and ensured ability to participate	Court: Video participation was authorized under §81.169, procedures were followed, and due process was not violated given statutory safeguards and low risk of erroneous deprivation

Heller v. Doe by Doe, 509 U.S. 312 (discussion of civil commitment liberty interests)
Mathews v. Eldridge, 424 U.S. 319 (procedural‑due‑process balancing test)
U.S. v. Baker, 45 F.3d 837 (5th Cir.) (upholding use of video conferencing in civil commitment context)
State v. Addington, 555 S.W.2d 569 (Tex. 1979) (clear and convincing standard for civil commitment)
Ex parte Granviel, 561 S.W.2d 503 (Tex. Crim. App.) (presumption of statute validity in facial constitutional challenge)
State v. K.E.W., 315 S.W.3d 16 (Tex. 2010) (review standards for findings requiring heightened proof)