In Re the Necessity for the Hospitalization of Tracy C.
2011 Alas. LEXIS 28
| Alaska | 2011Background
- Tracy C was involuntarily committed for 30 days to API; the petition alleged gravely disabled status and danger to self/others.
- A commitment hearing occurred on October 27 after petitions filed October 23 and screening at API.
- The probate master found Tracy gravely disabled based on acute manic/psychotic symptoms at admission, though improved by hearing.
- The superior court adopted the master's findings; Tracy challenged on grounds that commitment should rely on hearing-time condition.
- This appeal is moot but falls within the public-interest exception because it raises statutory-interpretation questions relevant to future cases.
- The Alaska Supreme Court held that (i) commitment must be based on condition at the commitment hearing, (ii) recent behavior and conditions may be considered alongside hearing symptoms, and (iii) the superior court correctly applied the statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal is moot but within the public-interest exception. | Tracy argues the question is of statutory interpretation capable of repetition. | API argues mootness should defeat review. | Public-interest exception applies; merits reviewed. |
| Whether the statute requires gravely disabled at hearing time, not admission time. | AS 47.30.735(c) should look to admission. | Commitment based on hearing-time condition. | Commitment must be based on hearing-time condition. |
| Whether recent behavior may be considered in determining gravely disabled. | Recent acts should not be ignored. | Only hearing-time symptoms matter. | Recent behavior/condition may be considered alongside hearing symptoms. |
| Whether the court properly applied AS 47.30.735 and related provisions. | Court relied on wrong time-point. | Statute correctly applied. | Statute correctly applied; findings supported. |
Key Cases Cited
- Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (discusses mootness and gravely disabled standard; recent acts allowed to be considered)
- Bigley v. Alaska Psychiatric Inst., 208 P.3d 168 (Alaska 2009) (statutory-interpretation questions may be repeated; public interest favored)
- E.P. v. Alaska Psychiatric Inst., 205 P.3d 1101 (Alaska 2009) (mootness and public policy considerations in commitment cases)