In the Interest of R.F.

Summary

The North Dakota Supreme Court affirmed a district court order requiring R.F., who had bipolar disorder and early-stage dementia, to undergo inpatient hospitalization and treatment for up to 90 days. The court held that the evidence supported the finding that less-restrictive alternatives were not currently adequate to meet his treatment needs or protect him from harm, although a dissent would have remanded for more thorough consideration of alternative placements.

Holdings

1. The district court did not clearly err in ordering inpatient hospitalization because the record supported its finding, by clear and convincing evidence, that a treatment program other than hospitalization was not currently suitable for R.F.'s treatment needs.

Questions Presented

1. Whether the district court clearly erred by finding that inpatient hospitalization was the least-restrictive treatment condition necessary to meet R.F.'s treatment needs and prevent harm to himself or others.
2. Whether the evidence clearly and convincingly established that treatment alternatives other than hospitalization were inadequate or unsuitable.

Disposition

affirmed