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330 P.3d 774
Wash.
2014
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Background

  • Morgan, diagnosed with schizophrenia, faced a 2008 SVP commitment trial after competency concerns arose.
  • A guardian ad litem (GAL) was appointed to represent Morgan’s interests during proceedings.
  • The trial court ordered involuntary medication to control Morgan’s delusions for trial purposes.
  • Morgan was found to be an SVP by a unanimous jury and is confined in the Special Commitment Center.
  • Morgan challenged the commitment on due process/competency and public-trial grounds; the Court affirmed the commitment.
  • Pretrial in-chambers discussions regarding involuntary medication occurred with Morgan absent and were later supported by written reports.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Must Morgan be competent to stand SVP trial? Morgan State No explicit competency requirement for SVP trial; due process satisfied
Did the in-chambers conference violate the public trial right? Morgan State No; proceedings open on record; no closure of core proceedings

Key Cases Cited

  • In re Det. of Stout, 159 Wn.2d 357 (2007) (procedural due process protections for SVP proceedings)
  • In re Young, 122 Wn.2d 1 (1993) ( SVP framework and treatment considerations)
  • McCuistion, 174 Wn.2d 369 (2012) (extensive protections in SVP statute; supports due process robustness)
  • In re Thorell, 149 Wn.2d 724 (2003) (SVP structural protections and statutory framework)
  • In re D.F.F., 172 Wn.2d 37 (2011) (open record access and public nature of SVP proceedings)
  • Kansas v. Hendricks, 521 U.S. 346 (1997) (recognizes substantial procedural protections in SVP schemes)
  • In re Det. of Cubbage, 671 N.W.2d 442 (Iowa 2003) (competency considerations and SVP procedures)
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Case Details

Case Name: In re the Detention of Morgan
Court Name: Washington Supreme Court
Date Published: May 8, 2014
Citations: 330 P.3d 774; 180 Wash. 2d 312; No. 86234-6
Docket Number: No. 86234-6
Court Abbreviation: Wash.
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    In re the Detention of Morgan, 330 P.3d 774