In the Interest of RB, State of Wyoming, By and Through the Office of the Park County Attorney v. Wyoming State Hospital and RB
2013 WY 15
| Wyo. | 2013Background
- RB was involuntarily hospitalized in Park County after emergency detention for safety concerns.
- The State Hospital notified a discharge plan after detox and stabilization on psychotropic meds.
- Park County Attorney objected, seeking a hearing on the merits of discharge on public-interest grounds.
- The district court ruled Park County had no statutory right to object or demand a hearing.
- The issue presented is whether a county attorney may object to discharge under Wyoming’s involuntary hospitalization statutes.
- Statutory framework assigns initial proceedings to county attorneys, but discharge decisions are medical determinations by the hospital head.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority of county attorney to object to discharge | Park County asserts statutory right to object under § 25-10-116. | RB argues only patient may contest discharge; county not authorized. | County attorneys have no authority to object to discharge. |
Key Cases Cited
- Jones v. United States, 463 U.S. 354 (U.S. 1983) (due process and release timing in civil commitment)
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (state interests in treatment balanced with due process)
- Reiter v. State, 36 P.3d 586 (Wyo. 2001) (due process and standard for commitment/detainment)
- In re Osenbaugh, 10 P.3d 544 (Wyo. 2000) (statutory interpretation guiding intent)
- KP v. State, 102 P.3d 217 (Wyo. 2004) (interpretation of statutory purpose and harmony)