Pryatel v. Doe

Summary

The North Dakota Supreme Court affirmed an order continuing Jane Doe’s involuntary treatment at the North Dakota State Hospital. The court held that clear and convincing evidence supported findings that Doe was mentally ill, presented a serious risk of harm to herself, and required treatment. The court also upheld the determination that less restrictive alternative treatment was not adequate or presently available.

Holdings

1. The district court did not clearly err in finding that Jane Doe was mentally ill and that, without hospitalization, there was a serious risk of harm to her based on substantial deterioration in physical and mental health.
2. The district court did not clearly err in finding that alternative treatment was not presently adequate to meet Doe's treatment needs or prevent harm to her or others.

Questions Presented

1. Whether clear and convincing evidence supported the district court's finding that Jane Doe was a mentally ill person requiring treatment.
2. Whether a less restrictive alternative treatment program was adequate to meet Doe's treatment needs and prevent harm to her or others.

Disposition

affirmed