Detention Of C.A.A.

CourtCourt of Appeals of Washington
DecidedMay 21, 2024
Docket58800-5
StatusUnpublished

This text of Detention Of C.A.A. (Detention Of C.A.A.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Detention Of C.A.A., (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

May 21, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Detention of: No. 58800-5-II

C.A.A.,

Appellant. UNPUBLISHED OPINION

PRICE, J. — As a result of threats against an employee of a grocery store, C.A. was charged

with the crime of felony harassment. However, C.A., who suffered from mental illness, was

deemed to be incompetent to stand trial and unlikely to be restored. Pursuant to the process for

felony-based commitment under the “Involuntary Treatment Act” (ITA), chapter 71.05 RCW, the

superior court dismissed the charges and permitted C.A. to be held in the county jail for up to

14 days prior to transport to Western State Hospital (WSH). Soon thereafter, the superior court

ordered C.A. to be committed for 180 days of involuntary treatment. The superior court found

that commitment was justified under the ITA’s felony-based commitment procedure, but it also

found, separately, that C.A. was gravely disabled.

C.A. appeals the superior court’s order, arguing that (1) the State failed to prove C.A.

committed a felony as required by felony-based commitment under the ITA, (2) the ITA violates

the First Amendment because it does not require the State to prove an individual’s mental state for

felony-based commitment when the underlying crime involves speech, and (3) the superior court

did not have any authority to order C.A. to be held in the county jail for up to 14 days after

dismissing the criminal charge against him.

We affirm. No. 58800-5-II

FACTS

In October 2022, C.A. was lying on the ground in front of the entrance to a grocery store,

obstructing people who were heading out to the parking lot. A security guard for the grocery store

asked C.A. to move, but C.A. ignored him. Unsure what C.A. would do next, the security guard

took out pepper spray from his pocket. Seeing the pepper spray, C.A. accused the security guard

of pointing a weapon at him and said several times, “You . . . just wait, I’m going to show you.”

Verbatim Rep. of Proc. at 32.

C.A. then stood up, took out what appeared to be a gun, and pointed it at the security guard.

Fearing he was about to be killed, the security guard drew his own gun while continuing to hold

the pepper spray. Soon thereafter, the security guard pepper sprayed C.A., causing C.A. to retreat.

Law enforcement later found C.A. and placed him under arrest.

Based on the threats made to the security guard, the State charged C.A. with felony

harassment. C.A. later underwent a competency evaluation to determine whether he was

competent to stand trial. The resulting report stated that more likely than not, C.A. lacked the

capacity to assist in his own defense and that the chances of restoration would improve if C.A.

could receive involuntary mental health treatment. As noted in the report, C.A. had had a history

of involuntary mental health treatment (including 15 or 16 prior admissions to WSH over a nearly

twenty-year period), a lack of insight into his mental illness, and an unwillingness to accept

medication.

After a delay of several months without C.A. being admitted to competency restoration,

the superior court entered an “Order Dismissing Felony Charges and Directing Civil Commitment

Evaluation” pursuant to the felony-based involuntary commitment process in the ITA. As part of

2 No. 58800-5-II

its order, the superior court found that C.A. was incompetent to stand trial pursuant to RCW

10.77.010 and 10.77.050 and that it was unlikely that C.A.’s competency would be restored. The

superior court dismissed the charges against C.A. The superior court ordered C.A. committed to

WSH for up to 120 hours for the purposes of being evaluated for a civil commitment petition. The

superior court also ordered:

The defendant shall be held in the jail/detention facility for a maximum of 14 days pending admission to the state hospital for civil commitment evaluation. The defendant shall be released if the state hospital has not offered admission within 14 days. The defendant shall be transported to the state hospital by the jail/detention facility.

Clerk’s Papers at 37 (emphasis added).

Two weeks later, C.A. was admitted to WSH. Following C.A.’s admission, two WSH

mental health providers filed a petition for a 180-day civil commitment (WSH’s petition). WSH’s

petition alleged that (1) C.A. committed acts constituting felony harassment and C.A. presented a

substantial likelihood of repeating similar acts as a result of a behavioral health disorder; and (2)

C.A. was gravely disabled as a result of a behavioral health disorder.

The superior court held a hearing on WSH’s petition. WSH psychologist, Dr. Archer,

testified on behalf of the petition. According to Dr. Archer, C.A. experiences schizoaffective

disorder, bipolar type, as well as substance use disorder. Dr. Archer further explained that C.A.’s

disorders result in a lack of cognitive and volitional control. She also described occasions when

C.A. was placed in seclusion due to unsafe interactions causing danger to others and himself.

Testifying about the alleged grounds for commitment, Dr. Archer said that as a result of

his behavioral health disorder and escalating loss of volitional control, C.A. presented a substantial

likelihood of repeating acts similar to the charged criminal behavior. She also testified that C.A.

3 No. 58800-5-II

was gravely disabled because he was unable to meet his basic health and safety needs due to his

behavioral health disorder, which would place him at risk of serious physical harm.

Following the hearing, the superior court entered written findings of fact and conclusions

of law. The superior court found, in part, that the testimony established that C.A. committed acts

constituting the crime of felony harassment and that C.A. presented a substantial likelihood of

repeating acts similar to the charged criminal behavior. As a separate basis for commitment, the

superior court also found that C.A. was gravely disabled as a result of a behavioral health disorder.

Thus, the superior court ordered C.A. to receive up to 180 days of intensive inpatient treatment.

C.A. appeals.

ANALYSIS

C.A. challenges his commitment with three arguments. Two of C.A.’s arguments relate to

the superior court’s 180-day commitment order, while the third relates to the superior court’s order

authorizing C.A. to be held in the county jail pending his transport to WSH. First, C.A. contends

his commitment was unlawful because the State failed to prove the mens rea element of the

underlying crime of felony harassment. Second, C.A argues that if the ITA, through former RCW

71.05.280(3) (2022), does not require the State to prove the mens rea of felony harassment, then

the ITA violates the First Amendment. And third, C.A. argues that the superior court did not have

the authority to order that he be held for up to 14 days pending his transport to WSH.

I. C.A.’S 180-DAY COMMITMENT ORDER IS LAWFUL

C.A.’s first two arguments pertain to the portion of the superior court’s order that relates

to the ITA’s felony-based commitment provision—whether the State is required to prove the

person committed all elements of felony harassment, including the mens rea element, and whether

4 No. 58800-5-II

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