In re Involuntary Commitment of M.

2020 ME 99
CourtSupreme Judicial Court of Maine
DecidedJuly 16, 2020
StatusPublished
Cited by3 cases

This text of 2020 ME 99 (In re Involuntary Commitment of M.) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Involuntary Commitment of M., 2020 ME 99 (Me. 2020).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2020 ME 99 Docket: Kno-19-385 Submitted On Briefs: June 25, 2020 Decided: July 16, 2020

Panel: MEAD, GORMAN, HUMPHREY, HORTON, and CONNORS, JJ.

IN RE INVOLUNTARY COMMITMENT OF M.

HORTON, J.

[¶1] M. appeals from a judgment of the Superior Court (Knox County,

Mallonee, J.) affirming the order of the District Court (Rockland, Sparaco, D.C.J.)

committing M. to involuntary hospitalization for up to 120 days. See 34-B M.R.S.

§ 3864 (2020). M. argues that the absence of a complete transcript of the

commitment hearing deprives her of due process and that the court’s findings

are not supported by evidence in the record.1 We affirm the judgment.

I. BACKGROUND

[¶2] In March 2019, the Department of Health and Human Services filed

a petition for M.’s involuntary commitment to a psychiatric hospital.

See 34-B M.R.S. §§ 3863(5-A)(B), 3864(1) (2020). The court appointed counsel

for M. and, on April 8, 2019, held a hearing on the petition. At M.’s request, the

1 We conclude that the remaining arguments in M.’s briefs are unpersuasive, and we do not address them in this opinion. 2

court held the hearing at Penobscot Bay Medical Center, where she was

receiving treatment. See id. § 3864(5)(B). The court arranged for the audio of

the hearing to be transmitted simultaneously by telephone to the courthouse,

where the audio of the proceeding was recorded using the court’s electronic

recording system. See id. § 3864(5)(G).

[¶3] During the hearing, M.’s treating physician and the court-appointed

psychiatric examiner testified in support of the Department’s petition. See id.

§ 3864(5)(F). The examiner also prepared a written report based on her

interview with M. See id. § 3864(4). M. testified against an involuntary

commitment.

[¶4] At the conclusion of the hearing, the court found, by clear and

convincing evidence, that (1) M. is mentally ill and that her mental illness poses

a “[l]ikelihood of serious harm,” as that term is defined in 34-B M.R.S.

§ 3801(4-A) (2020); (2) there are no adequate community resources for M.’s

care and treatment; (3) inpatient hospitalization is the best available means for

M.’s treatment; and (4) the Department had presented a satisfactory individual

treatment plan. See id. § 3864(6)(A). Based on these findings, the court

authorized M.’s hospitalization for up to 120 days. See id. § 3864(7). 3

[¶5] M. filed a timely appeal to the Superior Court. See id. § 3864(11);

4 M.R.S. § 105(3)(B)(4) (2020); M.R. Civ. P. 76D. When the transcript of the

hearing was filed, it contained many instances of the word “indiscernible” in

parentheses, indicating that the transcriber could not determine from the

recording what words were spoken.2 M. did not move to rectify the

indiscernible portions of the transcript, despite the existence of procedural

rules for doing so. See M.R. Civ. P. 76F(b), 76H(e)(4).

[¶6] The Superior Court (Mallonee, J.) affirmed the District Court’s

(Sparaco, D.C.J.) judgment, and M. timely appealed to us, see

M.R. App. P. 2B(c)(1).

[¶7] Given the numerous indiscernible words and phrases in the audio

recording and the transcript, we sua sponte ordered the parties to prepare a

statement of the evidence pursuant to M.R. App. P. 5(d). Our order had the

stated purpose of “improv[ing] the completeness and accuracy of the District

Court record to the maximum extent possible.” We expressly permitted the

parties, as necessary, to “use the existing transcript as a source of information,”

2 We have reviewed the audio recording from which the transcript was created. Our review

confirms that the transcriber accurately transcribed the words that can be discerned from the recording. It is apparent that the recording itself failed to capture certain words that were spoken at the hearing, likely because the proceeding was being recorded over the telephone. The omissions in the transcript consist of words and occasional phrases, but not lengthy portions of testimony. 4

“obtain information from witnesses or others present at the hearing,” and

“consult with the District Court itself.”

[¶8] The parties submitted a Rule 5(d) statement to the District Court.

See M.R. App. P. 5(d)(3). This statement was slightly more than one page in

length and summarized the testimony at the hearing in three short paragraphs,

without attempting to address or clarify any of the indiscernible portions of the

audio recording and transcript. The court approved the statement, and it

became part of the record on appeal. See id. M. did not object to the statement

of the evidence approved by the court, and M. does not argue on appeal that the

statement is deficient or inaccurate.

II. DISCUSSION

[¶9] M. argues that the State’s inability to provide a complete transcript

of her commitment hearing deprives her of due process and that the record

contains insufficient evidence to support the court’s findings. Before reaching

these contentions, we consider whether M.’s appeal is moot given that she is no

longer subject to involuntary commitment pursuant to the order she challenges

on appeal. 5

A. Mootness

[¶10] The court authorized M.’s involuntary commitment for up to

120 days, beginning on April 8, 2019. Therefore, the order expired no later than

August 6, 2019, and we must dismiss M.’s appeal as moot unless an exception

to the mootness doctrine applies. Cf. In re Steven L., 2014 ME 1, ¶¶ 5-9,

86 A.3d 5 (dismissing an appeal from an order of admission to a progressive

treatment program because the order had expired and no mootness exception

applied).

[¶11] Our mootness doctrine is well established in the context of

involuntary commitment proceedings:

Because the term of [M.’s] involuntary commitment has expired, [her] appeal should be dismissed as moot unless one of the exceptions to the mootness doctrine is present. The collateral consequences exception allows the review of a controversy where sufficient collateral consequences result from the appealed matter so as to justify relief. The public interest exception permits questions of great public interest to be addressed to guide the bar and public. A third exception allows the review of matters that are repeatedly presented to trial courts, but they are of such short duration that they escape appellate review.

In re Walter R., 2004 ME 77, ¶ 9, 850 A.2d 346 (citations omitted).

[¶12] When the court determines that an order of involuntary

commitment is warranted, it “may order commitment to a psychiatric hospital

for a period not to exceed 4 months in the first instance and not to exceed 6

one year after the first and all subsequent hearings.” 34-B M.R.S. § 3864(7).

Accordingly, there is a significant collateral consequence that results from an

individual’s first involuntary commitment pursuant to section 3864, and we

will reach the merits of M.’s appeal, even though the court’s order has expired,

if this is M.’s first time being subjected to involuntary hospitalization. See In re

Walter R., 2004 ME 77, ¶¶ 9-11, 850 A.2d 346.

[¶13] There is some evidence in the record suggesting that M. was

hospitalized about thirty-three years ago. However, the Department did not

seek to have M. committed for more than four months, and the court stated at

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