In re Steven L.
2014 ME 1
| Me. | 2014Background
- Steven L. was involuntarily admitted to Acadia Hospital for up to 90 days (order dated June 22, 2012).
- The district court ordered admission to a progressive treatment program for 12 months after a September 7, 2012 hearing, based on statutory findings.
- Steven appealed the involuntary admission; the Superior Court affirmed; the term expired September 7, 2013.
- Steven was discharged when the program term expired, before briefing was completed on appeal.
- The Supreme Judicial Court dismissed the appeal as moot, concluding none of the mootness exceptions applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal is moot and should be dismissed | Steven | Dix Center argues mootness; no expedited relief sought | Appeal dismissed as moot. |
| Collateral consequences exception applies | Steven | No collateral consequences from prior order modify future terms | Collateral consequences exception does not apply. |
| Public interest exception applies | Steven | Issue not of sufficient public interest or repeat nature | Public interest exception does not apply. |
| Case will not be repeatedly presented or quickly finalizable | Steven | Issue unlikely to recur; not short-term | Not a basis to reach merits. |
Key Cases Cited
- In re Walter R., 850 A.2d 346 (2004 ME 77) (mootness exceptions analysis; collateral considerations discussed)
- In re Christopher H., 12 A.3d 64 (2011 ME 13) (public interest and repeat-proceedings considerations in involuntary commitment)
- In re Kevin C., 850 A.2d 341 (2004 ME 76) (reiterated mootness framework in involuntary commitments)