State Of Washington v. William D. Thompson, 74747-9

Harborview Hospital petitioned to involuntarily detain and treat W.T. for up to 14 days based on psychosis and grave disability.
Evaluating clinicians (a nurse and psychologist Dr. Shaffer) reported W.T. was psychotic, gravely disabled, and that they could not recommend a less restrictive alternative.
At the probable cause hearing Dr. Shaffer testified W.T. was currently psychotic with manic features, unpredictable, noncompliant with treatment, and posed risk to himself and others.
W.T. testified he feared his family was trying to kill him and described delusional beliefs that supported the clinicians’ concerns.
The trial court found by a preponderance that W.T. was gravely disabled and posed a substantial risk of harm and ordered involuntary commitment, but did not enter an explicit written finding that less restrictive alternatives were not in the best interests of W.T. or others.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether omission of an express written finding that less restrictive alternatives are not in the person’s or others’ best interests requires reversal	W.T.: reversal required because RCW 71.05.240(3)(a) and LaBelle require explicit findings on less restrictive alternatives	State: oral findings and record evidence (including clinicians’ declarations and testimony) cure any deficiency in the written form	Affirmed — oral ruling and record adequately show the court considered and rejected less restrictive alternatives, so reversal not required here
Whether oral findings can supplement inadequate written findings	W.T.: oral remarks insufficient to meet LaBelle’s requirement for express written findings	State: LaBelle permits oral findings or record statements to supplement written findings	Court: Agrees oral findings/record may supplement written findings; here the incorporated oral ruling and expert testimony supplied the factual basis

In re Petition of LaBelle, 107 Wn.2d 196 (1986) (trial court must include findings indicating it considered statutory criteria and factual basis for concluding less restrictive treatment would not suffice)
Dunne v. McLaughlin, 100 Wn.2d 832 (1983) (due process limits on involuntary commitment)
State v. Agee, 89 Wn.2d 416 (1978) (purpose of findings requirement: show judge addressed all issues and permit meaningful review)
Roberts v. Ross, 344 F.2d 747 (3d Cir. 1965) (quoted authority on the purpose of findings and conclusions)
Groff v. Dep't of Labor & Indus., 65 Wn.2d 35 (1964) (findings must indicate factual bases for ultimate conclusions)