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2020 ME 39
Me.
2020
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Background

  • K. was arrested (June 19, 2019) on burglary and theft charges and, after a mental health exam, was transferred to the Maine State Prison mental health unit (July 29, 2019).
  • The Department of Corrections filed an application under 34‑A M.R.S. § 3049 seeking involuntary antipsychotic medication and an emergency ex parte order; the application was supported by one prescribing psychiatrist and a second qualifying psychiatrist as required.
  • The court granted an ex parte emergency order authorizing immediate medication and scheduled a hearing within ten days; the initial hearing was continued so the supporting psychiatrist could appear.
  • After a continued hearing, the court found by clear and convincing evidence that statutory grounds for involuntary medication were met and ordered 120 days of treatment (Aug. 12, 2019).
  • K. timely appealed, alleging evidentiary and procedural errors at the hearing; by the time of appellate briefing K. was no longer at the prison unit, the 120‑day order had expired, and K. had been found incompetent to stand trial.
  • The Supreme Judicial Court dismissed the appeal as moot, concluding none of the mootness exceptions applied, and therefore did not reach the merits.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Justiciability / Mootness Appeal remains justiciable; exceptions to mootness apply (questions of public concern; capable of repetition) Appeal is moot: K. is no longer subject to the order and would receive no practical relief Appeal dismissed as moot; exceptions to mootness not satisfied
Evidentiary and procedural errors at the involuntary‑treatment hearing Trial errors occurred (e.g., objections to testimony; continuance and witness issues) and should be reviewed on appeal Either procedures were proper or, alternatively, appeal is moot so errors need not be addressed Court declined to reach the merits of these contentions because the appeal is moot

Key Cases Cited

  • Anthem Health Plans of Me., Inc. v. Superintendent of Ins., 18 A.3d 824 (discusses mootness and when judicial resources should be applied)
  • In re Involuntary Treatment of S., 221 A.3d 135 (addresses mootness doctrine in involuntary treatment appeals)
  • In re Steven L., 153 A.3d 764 (notes best practice of seeking expedited appellate review where mootness is looming)
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Case Details

Case Name: In re Involuntary Treatment of K.
Court Name: Supreme Judicial Court of Maine
Date Published: Mar 31, 2020
Citation: 2020 ME 39
Court Abbreviation: Me.
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    In re Involuntary Treatment of K., 2020 ME 39