In the Interest of: D.W., In the Interest of: D.W. No. 1544 MDA 2016

Appellant D.W., an inmate at SCI Rockview, was diagnosed with unspecified psychosis and prescribed antipsychotic medication and therapy but repeatedly refused medication and minimally participated in therapy.
In early August 2016, after receiving bad news about his court case, D.W. made credible suicidal threats and expressed paranoid delusions involving specific prison staff, prompting seclusion to prevent confrontations.
Dr. Kevin Burke, SCI Rockview psychiatrist, testified that D.W. posed a danger to himself and others and that, absent treatment, he would likely act on suicidal threats within 30 days.
The prison filed a petition under 50 P.S. § 7304 seeking up to 90 days of involuntary psychiatric treatment; a mental health review officer granted the petition after a hearing on August 18, 2016.
D.W. petitioned for review in the Court of Common Pleas, which denied relief on August 25, 2016; D.W. appealed to the Superior Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence sufficed to show a "clear and present danger" under § 7301(b)(2)(i) to justify involuntary treatment	D.W.: prison presented insufficient evidence of a reasonable probability of death, serious bodily injury, or serious physical debilitation within 30 days	Commonwealth/Prison: psychiatrist testimony and recent emergence of credible suicidal threats, delusions, medication refusal, and poor therapy participation establish inability to care for self and a reasonable probability of serious harm within 30 days	Court upheld commitment: record contains clear and convincing evidence meeting § 7301(b)(2)(i)

Gibson v. DiGiacinto, 439 A.2d 105 (Pa. 1981) (reversed prisoner commitment where evidence did not show inability to attend to needs threatening death or serious injury)
Commonwealth v. Hubert, 430 A.2d 1160 (Pa. 1981) (MHPA standards apply strictly to incarcerated persons)
In re T.T., 875 A.2d 1123 (Pa. Super. 2005) (discussing strict interpretation of involuntary commitment statutes)
In re Hancock, 719 A.2d 1053 (Pa. Super. 1998) (clear and convincing evidence required for involuntary treatment)