In re Steven L., 153 A.3d 764

Steven L., a 55-year-old with longstanding schizoaffective disorder, had consecutive one-year involuntary progressive treatment program (PTP) orders beginning in 2012 and 2014; Dorothea Dix sought a 12-month extension in June 2015.
The District Court (Bangor) held a hearing June 26, 2015, found by clear and convincing evidence that Steven met all statutory requirements for involuntary PTP admission, and granted the 12‑month extension.
Findings included: severe and persistent mental illness; past suicidality and aggression; benefit from an individualized treatment plan; available community supports; unlikelihood of voluntary compliance; and that court‑ordered compliance would prevent decompensation and enable safer community survival.
Steven appealed to the Superior Court; Superior Court affirmed on April 20, 2016; Steven appealed to the Supreme Judicial Court.
The 2015 PTP order had expired by the time of appeal, raising mootness concerns; the Court nonetheless applied an exception to consider the merits and affirmed the District Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot because the PTP order expired	Steven argued the appeal was moot under prior decision (Steven L. I) and thus could be dismissed	State argued exceptions to mootness may apply given determinate orders that recur and this case’s circumstances	Court applied the exception for repeatedly presented, determinate issues and reached the merits; appeal not dismissed
Whether the evidence was sufficient to support involuntary PTP commitment (clear and convincing standard)	Steven argued the record lacked sufficient competent evidence to satisfy statutory elements (e.g., risk of harm, unlikely voluntary compliance)	State asserted testimony and reports (psychologist, NP, psychiatrist, Steven) provided clear and convincing proof of each statutory element	Court held the record contained competent evidence supporting each statutory element by clear and convincing evidence and affirmed the order

In re Steven L., 86 A.3d 5 (Me. 2014) (prior decision involving same patient and discussion of mootness)
In re Christopher H., 12 A.3d 64 (Me. 2011) (exception to mootness for issues repeatedly presented because of determinate orders)
Pitts v. Moore, 90 A.3d 1169 (Me. 2014) (clear and convincing evidence standard when fundamental rights at issue)
In re Marcial O., 728 A.2d 158 (Me. 1999) (standard of review for involuntary commitment findings)
In re Walter R., 850 A.2d 346 (Me. 2004) (statutory time limits on commitment orders)