In Re The Detention Of J.M.
48752-7
| Wash. Ct. App. | May 9, 2017Background
- J.M. was civilly committed to Western State Hospital (WSH): initial 90-day order (Mar 2015), then a 180-day order (June 2015); doctors sought a second 180-day order in Nov 2015.
- Two treating clinicians (Dr. Crinean, clinical psychologist; Dr. Naficy, psychiatrist) testified J.M. has schizophrenia and obsessive-compulsive disorder and lacks insight into his illness.
- Clinicians described recent, concrete evidence of self-neglect in the community (plugging toilet, spoiled food, wandering in underwear, not using heat, chapped hands from compulsive washing) and predicted deterioration if medication is discontinued.
- J.M. denied having mental illness, disputed medication effects, lacked employment history or a reliable housing plan, and would not live with his mother; he claimed savings and possible relatives as supports.
- A jury found J.M. gravely disabled under RCW 71.05.020(17) and that a less restrictive alternative was appropriate; the trial court ordered detention up to 180 days while arranging placement.
- J.M. appealed the gravely disabled finding; the court of appeals reviews sufficiency of the evidence under the clear, cogent, and convincing standard.
Issues
| Issue | Plaintiff's Argument (J.M.) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove J.M. is "gravely disabled" under RCW 71.05.020(17)(a) (danger of serious physical harm from failure to provide for essential needs) | State failed to present sufficient, recent, tangible evidence tying inability to provide essential needs to mental disorder | Testimony and recent conduct show inability to meet essential needs due to mental disorder, creating high probability of serious harm without treatment | Court held evidence was sufficient to satisfy prong (a) and affirmed the jury verdict |
| Whether commitment could rest on either prong (a) or (b) of the gravely disabled definition | Argued prong (a)/(b) not met by evidence | Commitment may be sustained if either prong is satisfied; here prong (a) supported | Court concluded prong (a) satisfied; did not need to resolve prong (b) |
| Whether J.M.'s refusal to accept diagnosis/medication undermined clear, cogent, and convincing proof | J.M. pointed to improved hygiene at WSH and disputed symptoms and medication effects | Clinicians explained improvement resulted from enforced treatment; lack of outpatient insight predicts relapse and self-neglect if released | Court accepted clinicians' nexus between mental disorder, refusal of meds, and risk of serious harm |
| Sufficiency standard of review on appeal | N/A (procedural) | Appellate review views evidence in favor of prevailing party and asks whether substantial evidence supports finding under clear, cogent, convincing standard | Court applied standard and found substantial evidence supported the jury's finding |
Key Cases Cited
- In re Det. of Kelley, 133 Wn. App. 289 (2006) (standard for reviewing sufficiency of evidence in detention proceedings)
- In re Det. of LaBelle, 107 Wn.2d 196 (1986) (definition and proof requirements for "gravely disabled" under RCW 71.05.020(17))
- In re Pawling, 101 Wn.2d 392 (1984) (clarifies clear, cogent, and convincing standard means showing the proposition is highly probable)