In Re Mh2014-002674, 358 P.3d 609

Appellant, a deaf patient, refused voluntary inpatient psychiatric treatment; psychiatrists were court-ordered to evaluate her for involuntary treatment.
Appellant requested an American Sign Language (ASL) interpreter; the court had also directed the interpreter service be contacted.
No ASL interpreter was available within the 72-hour evaluation window; doctors instead conducted interviews by exchanging written questions and answers in English.
Both evaluating psychiatrists diagnosed serious mental illness and filed affidavits supporting a petition for court-ordered treatment (COT).
Appellant moved to dismiss, arguing the evaluations violated A.R.S. § 36-501(12)(a)(ii) (failure to provide an interpreter) and thus the affidavits were legally insufficient; the trial court denied the motion and ordered combined inpatient and outpatient treatment.
Appellant appealed; the appellate court reviewed statutory compliance and due process, affirmed the COT order, finding reasonable efforts to obtain an interpreter and effective written communication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to provide ASL interpreter during court-ordered psychiatric evaluations violated statutory/due process requirements	Appellant: statute requires evaluations in preferred language; absence of ASL interpreter rendered affidavits legally insufficient and violated due process	County/Hospital: statute requires only that “every reasonable attempt” be made; an interpreter was requested but none was available within time constraints; written communication sufficed	Affirmed: court found reasonable efforts to secure interpreter and effective written communication; no due process violation
Whether Americans with Disabilities Act (ADA) required an interpreter under these facts	Appellant: ADA mandates effective communication; ASL required for fair evaluation	County: ADA permits alternative means if communication is effective; written exchange was sufficient given time constraints and complexity	Held: ADA did not compel an interpreter where written communication was effective and interpreter unavailable in required timeframe

In re MH94–00592, 182 Ariz. 440 (App. 1995) (standard for not disturbing an involuntary-treatment order)
In re MH2007–001264, 218 Ariz. 538 (App. 2008) (court must adhere strictly to statutes governing involuntary treatment)
Randolph v. Rodgers, 170 F.3d 850 (8th Cir. 1999) (interpreting statutory language that explicitly mandates provision of an interpreter)
Tucker v. Tennessee, 539 F.3d 526 (6th Cir. 2008) (written communication can satisfy effective-communication requirement when adequate and no intentional discrimination)