In the Interest of D.Z.

Summary

The Supreme Court of North Dakota affirmed orders involuntarily committing D.Z. to the North Dakota State Hospital for up to 90 days and authorizing forced medication. The court held that D.Z. waived any objection to the timing of notice, that clear and convincing evidence established he was a mentally ill person requiring treatment and posed a serious risk of harm, and that hospitalization and medication were the least restrictive appropriate interventions.

Holdings

1. D.Z. waived any objection to the timeliness of the hearing notice by stating that he did not need additional preparation time and rejecting the trial court's offer to continue the hearing.
2. The trial court did not clearly err in finding by clear and convincing evidence that D.Z. was mentally ill, posed a serious risk of harm to himself and others if untreated, and was therefore a person requiring treatment.
3. The trial court did not clearly err in finding that alternative treatment was inadequate and that involuntary hospitalization was the least restrictive treatment necessary at the time of the hearing.
4. The trial court did not clearly err in authorizing treatment with prescribed medication because the statutory factors were established by clear and convincing evidence.

Questions Presented

1. Whether D.Z. received adequate notice of the hearing on the petition to extend his involuntary commitment.
2. Whether clear and convincing evidence established that D.Z. was a mentally ill person requiring treatment and presented a serious risk of harm to himself or others.
3. Whether involuntary hospitalization was the least restrictive adequate treatment alternative.
4. Whether the statutory requirements for authorizing treatment with prescribed medication were satisfied by clear and convincing evidence.

Disposition

affirmed