In the Matter of the Necessity for the Hospitalization of Danielle B., 453 P.3d 200

Danielle B., a 73-year-old with chronic schizoaffective disorder, has a long history of repeated hospitalizations and relapses after stopping medication.
In Feb. 2017 she was evicted, assaulted a police officer, taken to a hospital where she became aggressive, resisted medication, and was petitioned for evaluation and sent to Alaska Psychiatric Institute (API).
At API she again assaulted staff and required involuntary medication; an API psychiatrist testified she was actively symptomatic, lacked safe housing, and was unlikely to engage in outpatient care.
Danielle acknowledged mental illness and past partial benefit from medication but said she wanted talk therapy and refused to return to her longtime outpatient provider; she offered no concrete alternative treatment plan.
The standing master and superior court found by clear and convincing evidence that Danielle was mentally ill, gravely disabled, a risk to herself/others, and that no less restrictive outpatient alternative was feasible; the court ordered 30 days’ involuntary commitment.
Danielle appealed solely arguing the State failed to prove there was no less restrictive alternative; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved no less restrictive alternative exists	Danielle: State failed to prove community-based care/services were inadequate	State: Evidence showed Danielle wouldn’t engage in outpatient care, lacked housing, and posed risk — outpatient not feasible	Court: Affirmed — clear and convincing evidence no less restrictive alternative was available
Standard of review for commitment findings	Danielle: factual findings insufficient	State: deference to credibility findings; legal questions reviewed de novo	Court: Applied clear-error deference to facts and de novo review to legal question; affirmed commitment

In re Hospitalization of Connor J., 440 P.3d 159 (Alaska 2019) (requires clear and convincing proof that no less restrictive alternative exists)
In re Hospitalization of Naomi B., 435 P.3d 918 (Alaska 2019) (commitment authorized only if no feasible less restrictive alternative)
In re Hospitalization of Jacob S., 384 P.3d 758 (Alaska 2016) (courts must consider whether a less restrictive alternative would provide adequate treatment)
Wetherhorn v. Alaska Psychiatric Inst., 156 P.3d 371 (Alaska 2007) (factual findings in commitment proceedings reviewed for clear error)
In re Hospitalization of Mark V., 375 P.3d 51 (Alaska 2016) (upholding commitment where mental illness impaired ability to fend for self and posed risks)
Myers v. Alaska Psychiatric Inst., 138 P.3d 238 (Alaska 2006) (emphasizing constitutional protection of individual choice in commitment decisions)
In re Hospitalization of Lucy G., 448 P.3d 868 (Alaska 2019) (clarifying review standards and legal framework for involuntary hospitalization)