In re N.L., 476 Mass. 632

N.L. was emergency-admitted to a psychiatric facility and the hospital filed petitions for civil commitment (G. L. c. 123, §§ 7 & 8) and for involuntary antipsychotic treatment (G. L. c. 123, § 8B).
Counsel was appointed but received medical records late; an independent psychiatrist met N.L. the day before the scheduled hearing.
On the day of the hearing counsel made his first request to continue so he and the independent examiner could prepare; the hospital opposed delay on safety grounds.
The judge denied the continuance without stated reasons, held the commitment hearing, ordered six months’ involuntary commitment, and immediately authorized involuntary antipsychotic treatment.
N.L. was later discharged and his appeal was moot, but the court exercised discretion to decide the legal issue presented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a judge must grant a first continuance requested under G. L. c. 123, § 7(c) or § 8B(c)	N.L.: denial of first continuance prevented meaningful preparation and prejudiced defense	Hospital: delay would jeopardize patient safety and treatment needs	Grant of a first continuance is mandatory when denial is reasonably likely to prejudice ability to prepare a meaningful defense; length left to judge’s discretion and must be limited to what is reasonably necessary

Newton-Wellesley Hosp. v. Magrini, 451 Mass. 777 (2008) (commitment and treatment issues often involve matters capable of repetition yet evading review)
Acting Supt. of Bournewood Hosp. v. Baker, 431 Mass. 101 (2000) (commitment and procedural due process context)
Sullivan v. Brookline, 435 Mass. 353 (2001) (statutory language interpreted in light of legislative purpose)
Hashimi v. Kalil, 388 Mass. 607 (1983) (construction of statutory timing provisions)
Sullivan v. Ward, 304 Mass. 614 (1939) (interpretation of statutory exceptions and word "unless")
Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489 (1983) (procedures allowing temporary treatment while awaiting hearing)
Commonwealth v. Nassar, 380 Mass. 908 (1980) (noting the significant liberty interest implicated by involuntary commitment)