In Re Detention Of A.c.

CourtCourt of Appeals of Washington
DecidedJuly 5, 2022
Docket82967-0
StatusPublished

This text of In Re Detention Of A.c. (In Re Detention Of A.c.) 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
In Re Detention Of A.c., (Wash. Ct. App. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

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IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION ONE In the Matter of the Detention of: No. 82967-0-I A.C., PUBLISHED OPINION Appellant.

DWYER, J. — A.C. appeals from an order committing him to up to 14 days

of involuntary mental health treatment, contending that the petition for his

detention did not comply with the requirements of the involuntary treatment act

(ITA). This is so, A.C. asserts, because one of the signers of the petition did not

personally examine him. As the ITA did not require the person who signed the

petition to do so, we affirm.

I

A.C. was referred to a designated crisis responder after being taken into

custody on a federal probation violation after he was observed talking to himself

and behaving oddly. After evaluating A.C., the designated crisis responder filed

a petition for initial detention pursuant to the ITA. A.C. was admitted to Navos

Multicare Inpatient, an evaluation and treatment facility. On July 16, 2021, Navos

filed a petition to detain A.C. for up to 14 days of involuntary mental health

treatment. The petition alleged that as a result of a behavioral health disorder, For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82967-0-I/2

A.C. presented a likelihood of serious harm to others and/or other’s property and

was gravely disabled. It further explained that

[t]he Respondent suffers from a behavioral health disorder as evidenced by bizarre behavior, disorganization, paranoia, delusions, responding to internal stimuli, labile mood, and poor insight. Prior to current hospitalization, the Respondent was released from psychiatric hospitalization in June 2021. Continuing to decompensate, the Respondent was found sitting in a doorway talking to self and flapping hands. The Respondent was not able to identify mother as mother and yelled at her to cause fear for her safety and change locks of the home. The Respondent stopped taking all psychiatric medications. The Respondent has not been sleeping and may not be eating. At the hospital, the Respondent was placed in restraints for threats and agitation; code grey was called. During the DCR evaluation, the Respondent continued as paranoid and disorganized, unable to plan for safe discharge from police hold. The Respondent has a history of similar behaviors when decompensated, including violence. The Respondent is currently decompensated and unable to plan for basic health and safety needs.

The petition was signed by a social worker, a physician, and a licensed

mental health counselor. The licensed mental health counselor, Kassandra

Sparkmon, did not personally examine A.C., instead relying on information

available in his charts, consultation with his treatment team (including the

physician who signed the petition), and observations made during her limited

interactions with A.C. Sparkmon attempted to interview A.C., but terminated the

interview after a few minutes when he explained that he did not want to continue.

A.C. filed a motion to dismiss the petition on the basis that Sparkmon, one

of the two medical professionals who had signed the petition, had not examined

him. The trial court denied the motion, ruling that, under the circumstances

presented, the ITA does not require that the people who sign the petition have

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82967-0-I/3

personally examined the respondent. After a hearing, the trial court ordered that

A.C. be detained at Navos for up to 14 days of involuntary treatment.

A.C. appeals.

II

A.C. contends that the petition for 14 days of involuntary mental health

treatment did not meet the statutory requirements set forth in RCW 71.05.230

because one of the medical professionals who signed the petition had not

examined him prior to doing so. Under the circumstances presented, however,

there is no statutory requirement that the individuals signing the petition have

personally examined the respondent. Such a requirement is, instead, only

present when the petition is based on substance use disorder treatment. Thus,

A.C.’s claim of error fails.

The meaning of a statute is a question of law that we review de novo.

State v. Christensen, 153 Wn.2d 186, 194, 102 P.3d 789 (2004). In interpreting

a statute, a court’s primary obligation is to give effect to the legislature’s intent.

Christensen, 153 Wn.2d at 194. The inquiry begins with the plain language of

the statute. Christensen, 153 Wn.2d at 194. “A statute that is clear on its face is

not subject to judicial construction.” State v. J.M., 144 Wn.2d 472, 480, 28 P.3d

720 (2001). Instead, we are “‘required to assume the Legislature meant exactly

what it said and apply the statute as written.’” HomeStreet, Inc. v. Dep’t of

Revenue, 166 Wn.2d 444, 452, 210 P.3d 297 (2009) (quoting Duke v. Boyd, 133

Wn.2d 80, 87, 942 P.2d 351 (1997)).

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82967-0-I/4

The relevant requirements for a petition for up to 14 days of involuntary

mental health treatment are set forth by statute:

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Related

Duke v. Boyd
942 P.2d 351 (Washington Supreme Court, 1997)
HomeStreet, Inc. v. STATE, DEPT. OF REVENUE
210 P.3d 297 (Washington Supreme Court, 2009)
Duke v. Boyd
133 Wash. 2d 80 (Washington Supreme Court, 1997)
State v. J.M.
28 P.3d 720 (Washington Supreme Court, 2001)
State v. Christensen
102 P.3d 789 (Washington Supreme Court, 2004)
HomeStreet, Inc. v. Department of Revenue
166 Wash. 2d 444 (Washington Supreme Court, 2009)

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In Re Detention Of A.c., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-detention-of-ac-washctapp-2022.