In Re Tracy C.
249 P.3d 1085
| Alaska | 2011Background
- Tracy C was involuntarily committed for 30 days to the Alaska Psychiatric Institute (API).
- A petition for commitment was filed October 22, 2009 by Tracy’s husband, alleging gravely disabled status and risk of harm.
- A 30-day commitment hearing was held October 27, 2009 before a probate master and then the superior court.
- The master and court based the commitment on Tracy’s condition and symptoms at/around the time of admission, not strictly at the hearing.
- Dr. Muschevici testified Tracy had bipolar I with manic/psychotic features; by the hearing date she showed improvement but was described as still in an acute state.
- The superior court granted the 30-day involuntary commitment, and Tracy appealed; the issue on mootness was addressed under the public interest exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must commitment be based on condition at hearing, not admission? | Tracy argues gravely disabled status must exist at hearing. | API contends evidence from admission supports commitment. | Yes; based on condition at the hearing. |
| May the court consider recent behavior and condition when evaluating gravely disabled at the hearing? | Recent acts should show ongoing gravely disabled state. | Symptoms at hearing plus recent history justify gravely disabled finding. | Yes; recent behavior and condition may be considered along with hearing symptoms. |
| Is the public interest mootness exception applicable to review of involuntary commitment orders? | Appeal presents a question of statutory interpretation capable of repetition. | Appeal is moot because commitment term expired. | Public interest exception applies; court may decide merits. |
| Did the superior court correctly apply AS 47.30.735 and related statutes? | Finding based on admission-era symptoms misstates the statute. | Statute permits considering recent behavior; fulfillment at hearing suffices. | Yes; court properly applied the statute. |
Key Cases Cited
- Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (limits on commitment; allows consideration of recent acts in gravely disabled analysis)
- Bigley v. Alaska Psychiatric Inst., 208 P.3d 168 (Alaska 2009) (statutory interpretation of commitment and medication procedures)
- E.P. v. Alaska Psychiatric Inst., 205 P.3d 1101 (Alaska 2009) (mootness and public interest considerations in commitment)
- Holderness v. State Farm Fire & Cas. Co., 24 P.3d 1235 (Alaska 2001) (principles of independent statutory interpretation and related issues)
- Native Village of Elim v. State, 990 P.2d 1 (Alaska 1999) (principles of statutory interpretation and public policy)