State v. BB, 240 Or. App. 75

appellant, a 31-year-old woman with psychosis, paranoia, and command/visual hallucinations, faced involuntary civil commitment proceedings under ORS 426.005(1)(e)(A) for danger to self.
incidents October 2, 7, and 9 involved running away or fleeing amid alleged voice command hallucinations, resulting in minor injuries or risky behavior.
the trial court found a mental disorder and that, due to the disorder, appellant was dangerous to herself; commitment to Oregon Health Authority for up to 180 days followed.
expert witnesses opined appellant had a mental disorder (schizophrenia) and that she was dangerous to self (but one examiner found danger only to others).
the court credited the pattern of impulsive, command-driven flight as evidence of danger to self, and the state relied on past conduct showing risk of harm.
on appeal, appellant challenged the sufficiency of the evidence to prove danger to self; the court reversed, holding evidence legally insufficient to support danger to self.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence shows imminent danger to self	B.B. contends record lacks imminent self-harm risk	State argues patterns of flight show danger to self	Insufficient evidence to establish danger to self

State v. Olsen, 208 Or.App. 686 (2006) (near-term threat required; harm must be actual and serious)
State v. Judd, 206 Or.App. 146 (2006) (danger to self requires more than speculative harm)
State v. North, 189 Or.App. 518 (2003) (near-future risk must be non-speculative, serious)
State v. Roberts, 183 Or.App. 520 (2002) (pattern of self-destructive conduct must show imminent harm)
State v. Ayala, 164 Or.App. 399 (1999) (apprehensions without specific near-term threat are insufficient)
State v. Powell, 178 Or.App. 89 (2001) (poor judgment without demonstrated harm cannot support commitment)