In the Matter of the Necessity for the Hospitalization of Mabel B., In the Matter of the Necessity for the Hospitalization of: Sarah D., 485 P.3d 1018

Two adults (pseudonyms Mabel and Sarah) were subject to ex parte orders authorizing immediate delivery to a designated facility for a statutorily limited 72-hour psychiatric evaluation after emergency detentions.
Alaska Psychiatric Institute (API) was the primary designated evaluation facility but faced severe bed/staffing shortages in late 2018, delaying transports.
Mabel was held in a local hospital for 16–17 days before transport; Sarah was held for more than 14 days before transport.
Each requested review hearings while still detained; superior courts found probable cause and allowed continued detention pending transport.
The Supreme Court held the extended pre-evaluation detentions were not reasonably related to the statutory purpose of immediate 72-hour evaluation and vacated the superior court orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prolonged pre-evaluation custodial detention violates substantive due process	Lengthy (>14 days) detention without evaluation impermissibly burdens liberty; due process violated	Detention was lawful under ex parte orders; probable cause review sufficed; capacity shortages explain delay	Court applied Jackson reasonable-relation test and held detentions that long were not reasonably related to the limited purpose of immediate evaluation; violations of substantive due process — orders vacated
Appropriate standard for review of continued detention when transport delayed	Clear and convincing evidence required because liberty interest increases with duration	Probable cause standard appropriate for pre-evaluation review	Court did not adopt clear-and-convincing for every delay; applied Jackson reasonable-relation framework and found probable cause had been applied below but detention still unreasonable given delay and lack of adequate justification

Jackson v. Indiana, 406 U.S. 715 (1972) (duration of commitment must bear reasonable relation to its purpose)
In re Hospitalization of Gabriel C., 324 P.3d 835 (Alaska 2014) (statutory intent that respondents be transported immediately for 72-hour evaluation)
In re Hospitalization of Naomi B., 435 P.3d 918 (Alaska 2019) (standards for involuntary commitment reviewed)
Or. Advocacy Ctr. v. Mink, 322 F.3d 1101 (9th Cir. 2003) (state may not justify prolonged detention awaiting hospital admission by lack of funds/staff/facilities)
Trueblood v. Wash. State Dep’t of Soc. & Health Servs., 822 F.3d 1037 (9th Cir. 2016) (reasonable relation applies to delay from court order to evaluation)
Concerned Citizens of S. Kenai Peninsula v. Kenai Peninsula Borough, 527 P.2d 447 (Alaska 1974) (substantive due process framework and rational-basis burden)
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (totality of facts guides asserted denial of due process)