State v. T. C., 342 P.3d 1112

Appellant seeks reversal of an involuntary-commitment order under ORS ch. 426.
Court found appellant mentally ill but committed him to OHA rather than granting conditional release.
Appellant sought conditional release to his wife, who testified she would care for him.
Statutes ORS 426.130 and ORS 426.125 govern dispositional options and conditional release.
Record shows trial court could have grounded its decision on either lack of wife’s ability or best-interests concerns; amendments after 2013 do not apply to this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conditional release to spouse was appropriate	Appellant argues wife could care for him.	State argues wife’s ability was not proven.	Affirmed; conditional release not ordered.
Whether wife’s ability to care was proven by preponderance	Appellant contends evidence showed ability to care.	State asserts evidence did not establish ability to prevent self-harm.	Evidence insufficient to compel conditional release.
Whether conditional release was not in appellant’s best interest	Appellant contends best-interest assessment favored conditional release.	Court reasonably found best interests favored commitment due to risk and lack of tools.	Committed to OHA was appropriate on best-interest grounds.

State v. J. S., 253 Or App 119 (2012) (bound by trial court findings; review of legal conclusions)
State v. Brenhuber, 146 Or App 719 (1997) (preponderance standard in dispositional phase)
State v. Johnson, 335 Or 511 (2003) (appellate bound by trial court findings on persuasiveness of evidence)
State v. T. M., 229 Or App 325 (2009) (explains dispositional options for mentally ill: release, conditional release, or civil commitment)