In re: J.C.N., 460 Md. 371

Summary

The Maryland Court of Appeals held that the ten-day deadline for an involuntary admission hearing under Maryland Health-General Article § 10-632(b) begins when an individual is initially confined in an inpatient facility, not when the individual arrives at a hospital emergency department. The court also held that substantial evidence supported the administrative law judge’s finding, by clear and convincing evidence, that J.C.N. presented a danger to her own life or safety or that of others and satisfied the requirements for involuntary admission.

Holdings

1. The ten-day deadline for an involuntary admission hearing under Maryland Code, Health-General Article § 10-632(b) begins upon the individual's initial confinement in an appropriate inpatient mental-health facility, not upon arrival at an emergency department. Because J.C.N. was transferred to the psychiatric unit seven days before her hearing, the hearing was timely.
2. Substantial evidence supported the ALJ's finding by clear and convincing evidence that J.C.N. presented a danger to the life or safety of herself or others, satisfying the disputed element of Maryland Code, Health-General Article § 10-632(e).

Questions Presented

1. Whether the ten-day deadline for an involuntary admission hearing under Maryland Code, Health-General Article § 10-632(b) begins when an individual arrives at a hospital emergency department or when the individual is confined in an inpatient mental-health facility.
2. Whether substantial evidence supported the ALJ's finding, by clear and convincing evidence, that J.C.N. presented a danger to the life or safety of herself or others.

Disposition

affirmed