State v. T. L.

Summary

The Oregon Court of Appeals affirmed an involuntary commitment judgment under the expanded criteria for persons with chronic mental illness. The court held that prior commitments under the expanded criteria may qualify as prior hospitalizations for purposes of former ORS 426.005(1)(f)(C)(ii). The court also held that the evidence was sufficient to establish substantially similar symptoms and a reasonable medical probability of deterioration without treatment.

Holdings

1. Hospitalizations resulting from prior commitments under the expanded criteria of former ORS 426.005(1)(f)(C) may satisfy the requirement in former ORS 426.005(1)(f)(C)(ii) that the person was twice placed in a hospital or approved inpatient facility within the previous three years.
2. The evidence was legally sufficient to permit a rational factfinder to find by clear and convincing evidence that appellant exhibited symptoms substantially similar to those preceding his prior commitments and would, without treatment, deteriorate to become dangerous to himself or others or unable to meet his basic needs.

Questions Presented

1. Whether prior hospitalizations resulting from commitments under the expanded chronic-mental-illness criteria may satisfy the requirement in former ORS 426.005(1)(f)(C)(ii) that the person was twice placed in a hospital or approved inpatient facility within the previous three years.
2. Whether the evidence was legally sufficient to establish that appellant was exhibiting symptoms or behavior substantially similar to those preceding and leading to prior commitments under former ORS 426.005(1)(f)(C)(iii).
3. Whether the evidence was legally sufficient to establish that, without treatment, appellant would continue, to a reasonable medical probability, to deteriorate until becoming dangerous to himself or others or unable to meet his basic needs under former ORS 426.005(1)(f)(C)(iv).

Disposition

affirmed