In Re Hospitalization of Paige M., 433 P.3d 1182

A Neurobehavioral Consultants psychologist petitioned for Paige M.’s involuntary hospitalization under AS 47.30.700 after treating her for about a year; the petition noted a pre-petition interview one week earlier and attached clinic notes.
The superior court held an ex parte hearing the evening the petition was filed; only the psychologist and a Sitka Counseling & Prevention Services representative attended, and only the psychologist testified.
The court expressed concern it lacked needed information but asked the psychologist whether Paige was likely to harm herself; the psychologist said yes and the court issued an order authorizing hospitalization.
Police detained Paige that night; she was transported to Alaska Psychiatric Institute the next day and hospitalized several days.
Paige moved to vacate the order, arguing the court violated AS 47.30.700 by failing to ensure a post-petition screening interview with her and that the evidence did not support probable cause; the superior court denied the motion and Paige appealed.
The Alaska Supreme Court reversed, holding the court failed to conduct the post-petition screening interview required by AS 47.30.700 (absent a finding such an interview was not reasonably possible) and that the error was not harmless given the weak evidence supporting gravely disabled/serious-harm findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AS 47.30.700 requires a post-petition screening interview with the respondent if reasonably possible	Paige: statute requires a post-petition screening investigation that includes an interview with the respondent unless it is not reasonably possible	State: a pre-petition interview reflected in the petition sufficed; court need not require a new post-petition interview	Court: Post-petition interview is required if reasonably possible; petition’s pre-petition interview alone did not satisfy statute absent a finding post-petition interview was not reasonably possible
Whether the failure to conduct a proper screening investigation was harmless error	Paige: error prejudicial because evidence for hospitalization was weak	State: implied that the psychologist’s testimony and records were sufficient; error harmless	Court: Error was not harmless because evidence for findings (gravely disabled / likely to cause serious harm) was marginal, so reversal warranted

In re Hospitalization of Heather R., 366 P.3d 530 (Alaska 2016) (interpreting AS 47.30.700 to require respondent interview as part of screening investigation unless not reasonably possible)
Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (construing "distress" in gravely disabled definition to require incapacity preventing safe living outside controlled environment)