In Re Hospitalization of Linda M.
440 P.3d 168
Alaska2019Background
- Linda M. was criminally charged and found incompetent to stand trial by a district court, which committed her to Alaska Psychiatric Institute (API) for competency restoration and expressly prohibited involuntary medication under that order.
- While at API, Linda exhibited violent behavior (spitting, hitting staff and a patient); API filed superior court petitions for a 30-day civil commitment and for authorization to involuntarily medicate her with chlorpromazine (Thorazine) and diphenhydramine.
- Linda moved to dismiss or stay the superior-court civil proceedings, arguing the district court handling the criminal competency commitment was the only proper forum and that the civil court should defer under Sell and Alaska statutes.
- API sought emergency authorization for crisis medication; the superior court held emergency and full hearings, found Linda incapable of giving informed consent, and authorized both emergency and non-emergency involuntary medication.
- The superior court applied Alaska’s civil involuntary-medication standards (clear-and-convincing proof of incapacity and a judicial best-interests determination considering Myers and Minnesota factors) and concluded no less-intrusive alternatives existed.
- The Alaska Supreme Court affirmed, holding the superior court properly exercised jurisdiction over civil commitment and medication petitions and that its best-interests determination authorizing medication was supported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether superior court may hear civil commitment/involuntary-medication petitions while a district court has ordered competency commitment | Linda: civil medication decisions must be made by the criminal (district) court; Sell requires trial court consideration of forced medication | State/API: Sell permits separate civil (Harper-type) proceedings; Alaska statutes designate superior court as proper forum for involuntary medication | Superior court has jurisdiction; civil petitions may proceed concurrently with criminal competency commitments |
| Whether involuntary medication may be authorized absent trial-competency rationale | Linda: medication here was not necessary; court deferred to treating providers and failed to adequately consider alternatives and pregnancy risks | API: clear-and-convincing evidence of incapacity and that Thorazine was least-intrusive, medically appropriate choice; isolation ineffective | Court made independent best-interests determination, considered alternatives and risks, and permissibly authorized involuntary medication |
Key Cases Cited
- Sell v. United States, 539 U.S. 166 (2003) (sets four-part test for medicating a criminal defendant to restore competency and distinguishes Harper-type civil justifications)
- Washington v. Harper, 494 U.S. 210 (1990) (upholds involuntary medication in prisons on dangerousness grounds and supplies Harper-type framework)
- Myers v. Alaska Psychiatric Inst., 138 P.3d 238 (Alaska 2006) (requires independent judicial best-interests determination before medicating nonconsenting psychiatric patients)
- In re Hospitalization of Jacob S., 384 P.3d 758 (Alaska 2016) (describes statutory standards and clear-and-convincing burden for involuntary medication under Alaska law)
- Bigley v. Alaska Psychiatric Inst., 208 P.3d 168 (Alaska 2009) (discusses Minnesota factors and other considerations in involuntary-medication decisions)