State Of Washington, V. M.n.
81798-1
| Wash. Ct. App. | Jul 19, 2021Background
- M.N. (who usually lives in California) appeared uninvited at her ex-husband’s Washington home late at night, expressing delusions, talking about suicide, and alarming the children; the ex‑husband allowed her to stay one night.
- A designated crisis responder detained M.N. for an initial 72‑hour hold; Fairfax Hospital petitioned for an additional 14‑day involuntary commitment.
- Fairfax counselor Brian Hayden testified M.N. has bipolar I, was manic with psychotic features (delusions, auditory hallucinations, pressured speech, agitation), had limited sleep and intermittent eating, lacked insight into medication need, and was gravely disabled (he emphasized prong (b) but also agreed she was in danger from inability to meet essential needs).
- The commissioner found insufficient evidence for grave disability under RCW 71.05.020(23)(b) but concluded M.N. was gravely disabled under prong (a) (danger from failure to provide for essential needs); the superior court adopted and affirmed that order.
- M.N. appealed, challenging certain factual findings (sleep and likely deterioration/manage needs) and arguing the petitioner failed to prove grave disability under prong (a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether petitioner proved M.N. was gravely disabled under RCW 71.05.020(23)(a) | M.N.: evidence insufficient; expert primarily pursued prong (b) and could not strongly find prong (a) | Petitioner: testimony and unchallenged findings show delusions, lack of housing in WA, intermittent sleep/feeding, poor insight/judgment — high probability of serious harm from inability to meet essentials | Affirmed: substantial evidence supports grave disability under prong (a) |
| Whether challenged factual findings (incomplete sleep; would be unable to manage needs/face deterioration) are supported | M.N.: disputes findings about sleep and future deterioration | Petitioner: record shows minimal sleep first night, intermittent self‑care, no housing, poor insight — supports deterioration risk | Affirmed: findings supported by substantial evidence; unchallenged findings are binding |
Key Cases Cited
- In re Det. of LaBelle, 107 Wn.2d 196 (1986) (defines grave disability standard and requires recent, tangible evidence of inability to provide essential needs)
- In re Det. of A.S., 91 Wn. App. 146 (1998) (discusses substantial‑evidence standard in involuntary detention appeals)
- In re Det. of M.K., 168 Wn. App. 621 (2012) (clarifies that whether someone is gravely disabled is a legal question for the court)
- In re Det. of R.H., 178 Wn. App. 941 (2014) (holding that expired commitment orders can still present live issues because of collateral consequences)
- In re Det. of W.C.C., 193 Wn. App. 783 (2016) (unchallenged findings of fact are verities on appeal)