In re the Necessity for the Hospitalization of Jeffrey E.
281 P.3d 84
| Alaska | 2012Background
- Jeffrey E., 20, with recent job loss, divorce, and family concerns about hygiene and behavior, is brought to a hospital and evaluated for possible psychosis.
- He remains catatonic and uncommunicative; hospital notes possible psychosis but cannot determine active status; staff believe further assessment needed.
- Emergency petition for involuntary commitment is filed; API conducts examination following ex parte transport to API.
- API psychiatrist Cosgrove diagnoses psychotic disorder not otherwise classified; notes catatonia improves with medication and lack of insight risks nonadherence.
- Hearing on 30-day commitment occurs; court finds mentally ill, gravely disabled, and that API is the least restrictive capable facility; orders 80-day commitment.
- Jeffrey appeals challenging gravely disabled finding; appeal treated under collateral consequences exception due to first commitment and mootness not applicable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether gravely disabled finding at hearing was correct | Jeffrey contends he was not gravely disabled at the hearing. | State argues the court properly found gravely disabled based on current and recent risk factors. | Affirmed gravely disabled finding; future risk and lack of insight support view that he cannot live safely outside care. |
| Whether the court’s use of recent behavior supports gravely disabled status | Jeffrey argues recent functioning undermines gravely disabled conclusion. | State asserts recent behavior is probative and consistent with forward-looking gravely disabled standard. | Upheld: recent behavior admissible and supports forward-looking gravely disabled determination. |
| What standard governs review of gravely disabled determinations | Jeffrey says factual findings are reviewed for clear error with legal question de novo. | State contends both fact and legal conclusions receive appropriate deference per existing Alaska law. | Acknowledged: factual findings review for clear error; gravely disabled legal conclusion reviewed de novo. |
Key Cases Cited
- Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (collateral consequences mootness and reversibility standards for first involuntary commitment)
- In re Hospitalization of Tracy C., 249 P.3d 1085 (Alaska 2011) (recent behavior can inform gravely disabled analysis; forward-looking standard)
- In re Joan K., 273 P.3d 594 (Alaska 2012) (collateral consequences exception to mootness in involuntary commitments)
- In re Johnstone, 2 P.3d 1226 (Alaska 2000) (quoting and applying gravely disabled standards)
- Bigley v. Alaska Psychiatric Inst., 208 P.3d 168 (Alaska 2009) (requires consideration of distress and functional impairment in gravely disabled analysis)