In the Matter of M.W., Alleged to Be Seriously Mentally Impaired, M.W., 15-2213

M.W., with autism spectrum disorder and severe OCD, went to UIHC ER on Dec 4, 2015; a UIHC psychiatrist filed for involuntary hospitalization, alleging medication noncompliance, past violence off meds, and inability to live independently.
A judicial hospitalization referee held a Dec 8 hearing without notifying M.W.’s legal guardian (his mother), denied M.W.’s continuance request, and found him seriously mentally impaired, ordering psychiatric evaluation and treatment.
M.W. appealed to the district court, which declined to remand for a new referee hearing and set a de novo trial; UIHC later requested dismissal and the district court dismissed the case; M.W. pursued further appellate review.
The Iowa Supreme Court transferred the appeal to the Court of Appeals, which considered jurisdiction and mootness because the underlying commitment had been dismissed.
The Court of Appeals held it had jurisdiction to hear the appeal, invoked mootness exceptions (public importance and collateral consequences), found the guardian was entitled to notice under Iowa R. Civ. P. 1.305(3), and vacated the referee’s involuntary hospitalization order because the guardian did not receive notice. The court did not reach the adequacy of the evidence supporting serious mental impairment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate courts have jurisdiction over a referee’s commitment order without first obtaining de novo district-court review	M.W.: Referee’s order is a final appealable order; direct appeal is allowed under In re Melodie L.	State: Statute contemplates first appealing to district court; cannot bypass it	Court: Jurisdiction exists; Melodie L. permits direct appellate review of referee orders
Whether the appeal is moot after dismissal of commitment	State: Moot because commitment dismissed and no practical effect; exceptions don’t apply	M.W.: Collateral consequences and public‑importance exceptions justify review	Court: Appeal is moot but exceptions (public importance; collateral consequences) permit review
Whether guardian was entitled to notice of involuntary hospitalization proceedings	M.W.: Guardian must be served under Iowa R. Civ. P. 1.305(3); absence of notice violated rights	State: No notice required because patient was confined at a state hospital (or emergency exception)	Court: Guardian was entitled to notice; M.W. was not “confined” and no emergency exception applied
Remedy for lack of guardian notice	M.W.: Relief by vacating/refunding commitment	State: Error may not require reversal in all cases	Court: Violation makes order voidable; M.W. met prima facie defense; vacated referee’s order (no remand because commitment dismissed)

In re Melodie L., 591 N.W.2d 4 (Iowa 1999) (referee orders can be appealed directly to appellate courts)
Boomhower v. Cerro Gordo Cty. Bd. of Adjustment, 163 N.W.2d 75 (Iowa 1968) (right to appeal is statutory)
In re B.B., 826 N.W.2d 425 (Iowa 2013) (adjudication of serious mental impairment carries collateral consequences justifying appellate review)
In re M.T., 625 N.W.2d 702 (Iowa 2001) (public‑importance exception permits review of moot involuntary commitment appeals)
In re T.S., 705 N.W.2d 498 (Iowa 2005) (applied M.T. reasoning to broaden review in commitment contexts)
Conklin v. Conklin, 132 N.W.2d 459 (Iowa 1965) (guardian notice requirement protects ward and ensures full disclosure to court)
In re Guardianship of B.J.P., 613 N.W.2d 670 (Iowa 2000) (orders by lower judicial officers may be final and appealable)
In re D.W.K., 365 N.W.2d 32 (Iowa 1985) (juvenile court referee’s final decisions may be appealable)