In Re the Necessity for the Hospitalization of Reid K.
357 P.3d 776
Alaska2015Background
- Reid K., diagnosed with paranoid schizophrenia, experienced command auditory hallucinations urging mass violence and had prior medication noncompliance and substance (marijuana) use.
- In August 2013 Reid was voluntarily hospitalized after describing plans to kill members of his village and obtaining a firearm; treating psychiatrists sought involuntary commitment.
- On August 29, 2013 the superior court entered a 30-day involuntary civil commitment order after a contested evidentiary hearing where doctors testified Reid was likely to harm others and no less-restrictive alternative was adequate.
- After the 30-day period, Reid’s doctors petitioned for a 90-day commitment; at the 90-day proceeding Reid stipulated that he was mentally ill and likely to harm himself or others, and the court entered a 90-day commitment.
- Reid appealed the 30-day order, arguing insufficiency of the evidence; the State moved that the appeal was moot because the commitment period expired and Reid’s subsequent stipulated 90-day commitment subsumed any collateral consequences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appeal of expired 30-day commitment remains justiciable | Reid: Exceptions to mootness apply (public interest and collateral consequences), so review is appropriate | State: Commitment period expired; appeal moot and exceptions do not apply because subsequent 90-day commitment subsumes consequences | Appeal dismissed as moot; neither public interest nor collateral-consequences exceptions applied |
| Whether public interest exception applies | Reid: Issues (predictive methods, interpretation of "harm to others" and "least restrictive alternative") are repeatable and important | State: This is a fact-based sufficiency challenge, not a statutory-interpretation issue suited to the public-interest exception | Public interest exception does not apply; factual reliability challenges are for trial court and not an area justifying exception |
| Whether collateral-consequences exception applies | Reid: 30-day contested adjudication carries distinct collateral effects from later stipulated order | State: Any collateral consequences attach equally to the 90-day court-ordered commitment; no incremental harm from the 30-day order | Collateral-consequences exception does not apply; 90-day stipulated commitment subsumes consequences of 30-day order |
| Whether appeal should be remanded to consider ineffective assistance of counsel in stipulation | Reid: Requests remand to litigate whether counsel was ineffective in entering 90-day stipulation | State: Not addressed as primary; court requires showing both deficient performance and prejudice | Court declined remand — Reid failed to show counsel’s performance was below reasonable standard; mootness disposition affirmed |
Key Cases Cited
- In re Joan K., 273 P.3d 594 (Alaska 2012) (adopted collateral-consequences exception for involuntary commitments)
- In re Mark V., 324 P.3d 840 (Alaska 2014) (clarified showing needed for incremental collateral consequences after first commitment)
- Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (expired commitment appeals based on insufficiency of evidence are generally moot)
- Gilbert M. v. State, 139 P.3d 581 (Alaska 2006) (judicial notice of subsequent proceedings)
- Chloe W. v. State, Dep’t of Health & Soc. Servs., 336 P.3d 1258 (Alaska 2014) (standard for ineffective-assistance claims in civil proceedings)