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

Steven L., age 55, with longstanding severe and persistent mental illness (schizoaffective disorder), was subject to repeated involuntary progressive treatment program (PTP) admissions; the challenged 12‑month extension order was entered after a June 26, 2015 hearing.
Dorothea Dix Psychiatric Center sought the extension under 34‑B M.R.S. § 3873‑A(9), citing prior hospitalizations, dangerous behavior (including an overdose attempt and aggression), and Steven’s stated intent to stop medication.
The District Court found by clear and convincing evidence that each statutory condition for involuntary PTP admission was met and ordered a 12‑month extension.
Steven appealed to the Superior Court, which affirmed; he then appealed to this Court. More than 12 months elapsed after the District Court’s order, so the commitment order had expired at the time of this Court’s review.
The Court considered mootness sua sponte, concluded an exception applied (because the issue is determinate and likely to recur and involves the same patient), reached the merits, and upheld the sufficiency of the evidence supporting the commitment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness: Should the appeal be dismissed because the 12‑month order expired?	Steven argued the appeal is moot under this Court’s prior decision in In re Steven L. and that relief is unavailable.	State urged that an exception to mootness may apply given the determination and likelihood of recurrence; the Department took no position on mootness in briefing.	Court applied the exception for issues that are determinate/fleeting and likely to recur (same patient), reached the merits, and did not dismiss as moot.
Sufficiency of the evidence for involuntary PTP admission (statutory elements under § 3873‑A(1))	Steven argued the record lacked sufficient evidence to support the required findings (e.g., likelihood of serious harm, inability to comply voluntarily).	State relied on testimony and reports (psychologist, outpatient provider, former psychiatrist, Steven’s own statements) establishing each statutory element by clear and convincing evidence.	Court held the District Court’s findings were supported by competent evidence and not clearly erroneous; affirmed the commitment order.

In re Steven L., 86 A.3d 5 (Me. 2014) (prior decision involving same patient and appellate-mootness guidance)
In re Christopher H., 12 A.3d 64 (Me. 2011) (mootness exception for determinate orders likely to recur)
Pitts v. Moore, 90 A.3d 1169 (Me. 2014) (clear-and-convincing standard where fundamental rights are at issue)
In re Nicholas S., 140 A.3d 1226 (Me. 2016) (general mootness principles)
In re Walter R., 850 A.2d 346 (Me. 2004) (statutorily limited duration of commitment orders)