In the Matter of the Commitment of L.J.
A-3469-23
| N.J. Super. Ct. App. Div. | Jun 18, 2025Background
- L.J., an adult male, was involuntarily committed to Newark Beth Israel Medical Center in May 2024 after being found wandering and exhibiting disorganized, paranoid behavior.
- At his commitment hearing, Dr. Samuel Sostre, L.J.'s treating psychiatrist, diagnosed L.J. with schizophrenia and testified that L.J. was paranoid, had poor judgment, and was unable to care for himself or maintain a safe living environment.
- L.J. testified, disputed the schizophrenia diagnosis, and claimed he gave his mother's name and address but did not provide a phone number; no fact or expert witnesses testified on L.J.'s behalf.
- The trial judge found clear and convincing evidence of mental illness and danger to self, ordered continued commitment, and set a four-week review. L.J. was later discharged, but appealed seeking reversal and removal of the commitment record.
- On appeal, L.J. challenged the sufficiency of the evidence, alleged due process violations from the court's questioning of an unsworn social worker, and claimed insufficient findings of fact and reliance on improper evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence for Commitment | State failed to prove by clear, convincing evidence of danger | Record supports commitment; no new legal issue; moot | Commitment supported by credible evidence |
| Due Process—Unsworn Social Worker Testimony | Judge improperly elicited and relied on unsworn testimony | No prejudicial error; both counsel questioned SW; harmless | No plain error; no prejudice |
| Specificity of Findings | Judge failed to make adequate findings or support for ruling | Sufficient explanation given; decision complies with rules | Judge complied; findings supported |
| Mootness of Appeal | Not moot; liberty interest and likely repetition | Moot due to L.J.’s discharge; no practical relief available | Not moot; merits decided |
Key Cases Cited
- In re D.C., 146 N.J. 31 (scope of appellate review of commitment extremely narrow)
- In re Civ. Commitment of R.F., 217 N.J. 152 (trial judges’ expertise in commitment cases entitled to deference)
- State v. Johnson, 42 N.J. 146 (findings upheld if supported by sufficient credible evidence)
- In re Commitment of W.H., 324 N.J. Super. 519 (mere possibility of danger is insufficient for commitment)
- State v. Caraballo, 330 N.J. Super. 545 (witnesses must be sworn or affirmed)
- Baker v. Nat'l State Bank, 161 N.J. 220 (plain error should be sparingly employed in civil cases)
- Slutsky v. Slutsky, 451 N.J. Super. 332 (findings of fact and conclusions of law required in NJ bench trials)