In the Matter of N.L., SJC 12183

N.L. was emergency-admitted to a psychiatric hospital on Oct. 30, 2014; the hospital filed civil commitment (G. L. c. 123, §§ 7 & 8) and involuntary-medication (G. L. c. 123, § 8B) petitions on Nov. 3, 2014.
A hearing was set for Nov. 6; defense counsel received medical records only on Nov. 5 and an independent psychiatrist first met N.L. that day.
On Nov. 6 counsel moved for a continuance to permit preparation and completion of the independent evaluation; the hospital opposed, the judge denied the motion without stated reasons, and proceeded to order six-month commitment and authorize antipsychotic treatment.
N.L. appealed; the appeal became moot after his discharge, but the Supreme Judicial Court exercised discretion to decide the legal issue presented.
The core legal question concerned whether a judge must grant a first request to continue a G. L. c. 123, § 7 (c) or § 8B (c) hearing when denying it would reasonably prejudice the person’s ability to prepare a meaningful defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a first continuance request under G. L. c. 123, § 7(c) / § 8B(c) must be granted	N.L.: first request to continue was necessary to prepare, and denial likely prejudiced defense	Hospital: delay endangered patient safety and treatment needs	Grant of a first continuance is mandatory when denying it is reasonably likely to prejudice the person’s ability to prepare a meaningful defense
Whether the appeal is justiciable / mootness	N.L.: substantive error even if discharged; issue capable of repetition yet evading review	Hospital: discharge moots appeal	Appeal dismissed as moot, but court reached and decided the legal question as capable of repetition yet evading review
Requirement for judge's findings when denying continuance	N.L.: judge should explain why denial is not prejudicial	Hospital: implied that safety/urgency justify denial without detailed findings	If judge denies a requested continuance, she must state on the record particularized reasons why denial is not reasonably likely to prejudice preparation; review is for abuse of discretion

Newton-Wellesley Hosp. v. Magrini, 451 Mass. 777 (2008) (commitment and treatment issues are matters of public importance and often capable of repetition yet evading review)
Acting Supt. of Bournewood Hosp. v. Baker, 431 Mass. 101 (2000) (court previously addressing procedural protections for mentally ill persons)
Hashimi v. Kalil, 388 Mass. 607 (1983) (statutory interpretation of exceptions to timing rules)
Sullivan v. Brookline, 435 Mass. 353 (2001) (give effect to statutory language consistent with legislative intent)
Sullivan v. Ward, 304 Mass. 614 (1939) (interpretive principle regarding statutory conjunctions such as "unless")
Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489 (1983) (procedures exist to permit temporary treatment pending hearings)
Commonwealth v. Nassar, 380 Mass. 908 (1980) (noting the substantial liberty interests at stake in involuntary commitment)