Robert Louis Martin v. State, 14-14-00730-CV

Robert Louis Martin was found not guilty by reason of insanity for aggravated assault (2002) and committed to a state hospital; the court repeatedly extended his inpatient commitment over the years.
In 2006 Martin was released to outpatient care; in 2007 his outpatient supervision was revoked and he was recommitted to inpatient care, with subsequent extensions through 2014.
In June 2014 the hospital recommended release to outpatient care; the State sought another one-year renewal of Martin’s inpatient commitment.
On September 5, 2014, the trial court held a hearing and signed an order extending Martin’s inpatient commitment for one year.
Appellant challenged the renewal on appeal, arguing the evidence was legally insufficient because the trial court did not hear competent medical or psychiatric testimony as required by Health & Safety Code § 574.035(g).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally sufficient to renew inpatient commitment under § 574.035	Martin: Renewal insufficient because no competent medical/psychiatric testimony was presented at the hearing	State: Agreed no such testimony was presented but urged this court to reconsider precedent applying subsections (e) and (g) to these hearings	Court reversed and rendered: renewal order unsupported because § 574.035(g) required competent medical or psychiatric testimony at the hearing

Campbell v. State, 85 S.W.3d 176 (Tex. 2002) (holds criminal-commitment hearings are civil and must follow pertinent Mental Health Code provisions)
Campbell v. State, 125 S.W.3d 1 (Tex. App.—Houston [14th Dist.] 2002) (applies subsections (a) and (e) of § 574.035 to recommitment hearings)
Martin v. State, 222 S.W.3d 532 (Tex. App.—Houston [14th Dist.] 2007) (holds § 574.035(g) requires competent medical/psychiatric testimony at recommitment hearings)
Glassman v. Goodfriend, 347 S.W.3d 772 (Tex. App.—Houston [14th Dist.] 2011) (discusses panel stare decisis binding prior panel decisions)