In re K. D.

41 V.I. 57, 1999 WL 552769, 1999 V.I. LEXIS 19
CourtSupreme Court of The Virgin Islands
DecidedJune 29, 1999
DocketFamily No. IC 7/1999
StatusPublished
Cited by2 cases

This text of 41 V.I. 57 (In re K. D.) is published on Counsel Stack Legal Research, covering Supreme Court of The Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re K. D., 41 V.I. 57, 1999 WL 552769, 1999 V.I. LEXIS 19 (virginislands 1999).

Opinion

HOLLAR, Judge

MEMORANDUM OPINION

This matter is before the Court on an application for emergency commitment dated May 10, 1999 and a petition for involuntary commitment dated May 18, 1999. For reasons stated below, the application for emergency commitment is denied, and the petition for involuntary commitment is dismissed without prejudice.

I. FACTS AND PROCEDURAL POSTURE

On May 10,1999, petitioner, I. D., the mother of K. D., completed a pre-printed form captioned "Application For Emergency Com[58]*58mitment". Notwithstanding the fact that the form was addressed to the Administrator of St. Thomas/St. Croix Hospital, petitioner filed the form in this Court on May 18, 1999. The application is alleged to be made pursuant to V.I. Code Ann. tit. 19, § 722.

In the application, petitioner asserted, inter alia, that her son, K. D., the person for whom commitment is being sought, hallucinates and speaks to himself. Even though petitioner suspected that K.D. was using drugs, she readily conceded that K.D. had no past psychological history, had not threatened, attempted, or inflicted physical harm on himself or another, and there was no evidence that he was likely to do so. The ad damnum clause of the application requested that the Administrator commit K.D. for emergency mental treatment for the period of time permitted under V.I. Code Ann. tit. 19, § 722(e).

Two (2) pre-printed forms captioned "Petition For Involuntary Commitment" and "Certificate of Psychiatric Examination" were completed and filed in Court in addition to the application for emergency commitment. The unsworn petition for involuntary commitment, dated May 18,1999, alleged that K. D., the person to be committed: (1) was a mentally disturbed person, who habitually lacked self control due to his disturbed condition; and (2) was incapacitated by drugs. The "Certificate of Psychiatric Examination", prepared by Dr. Leighman Lu, and dated May 18, 1999 certified that K. D., the person to be committed, "will be " examined upon admission, within the time prescribed by V.I. Code Ann. tit. 19, § 723. Dr. Lu further certified that he found K.D. to be demonstrating aberrant behavior requiring emergency treatment, and that this finding was evidenced by the statement of K.D.'s mother, the petitioner. Contrary to the petitioner's assertions, however, Dr. Lu certified that K. D. was likely to inflict physical harm on himself or another, unless committed.

II. DISCUSSION

In an effort to address the application and petition, this Court will address the following issues: (1) whether this Court has any jurisdiction over an application for emergency commitment, pursuant to V.I. Code Ann. tit. 19, § 722; (2) whether a person may be committed to the custody of the Department of Health by the Court, [59]*59pursuant to V.I. Code Ann. tit 19. § 23(c), for the purpose of a diagnostic evaluation and treatment, before a hearing is conducted on the petition for involuntary commitment; and (3) whether a certificate of a licensed physician or mental health professional stating that the person to be committed "will be examined on admittance" satisfies the requirements of V.I. Code Ann. tit. 19, § 723(a).

A. This Court Lacks Jurisdiction Over An Application For Emergency Commitment

V.I. Code Ann. tit. 19, Chapter 31 provides for two methods for the involuntary commitment of a person. V.I. Code Ann. tit. 19, § 722 outlines the procedures required to have a person involuntarily committed to an approved public treatment facility for emergency treatment. The provision contemplates action to be taken by an Administrator for a very short period of commitment. Subsection (e) clearly states, in part, "No person committed under this section may be detained in any treatment facility for more than five days, not including holidays and weekends." V.I. Code Ann. tit. 19, §§ 723, on the other hand, outlines the procedures required for the Court to involuntarily commit a person to the custody of the Department of Health for an indefinite period or time certain.

Because these two sections are distinguishable by the source and the type of relief each affords, this Court is aghast at what appears to be a mix-and-match approach, employed by many, in applying these statutes.

Section 722 confers absolutely no authority upon the Court to act. All authority contained in § 722 is given to the Administrator of the approved public treatment facility. Under subsection (b), the emergency commitment process begins with a written application directed to the Administrator of an approved public treatment facility. The written application must be filed by the guardian, a spouse, the certifying physician or mental health professional, a relative of the person to be committed, or any other responsible person with personal knowledge of such person, and establish reasonable grounds to believe that the person whose commitment is sought is mentally disturbed to the extent that [60]*60emergency commitment and treatment is required to protect that person, or others, from danger of physical harm or injury. Reasonable grounds sufficient to warrant commitment may be established by alleging that the person to be committed is a mentally disturbed, intoxicated, or a drug dependant person who either (1) has threatened, attempted, or inflicted physical harm on himself or another and is likely to inflict physical harm on himself or another unless committed, or (2) is incapacitated by alcohol or drugs. V.I. Code Ann. tit. 19, § 722(a).

Immediately after the application has been received by the Administrator, a mental health professional must undertake an evaluation of the person to be committed. This evaluation may take place either in the field, in the home, or in the public treatment facility. Commitment for the purpose of examination and emergency treatment is mandated upon a determination by the mental health professional that the person poses a danger of physical harm to himself, or to others, or of damage to property. V.I. Code Ann. tit. 19, § 722(b).

Once the threshold determination is made, Section 722 confers upon the Administrator or mental health professional of the approved public treatment facility the authority to request that a peace officer take the person to an approved treatment facility for emergency examination and/or treatment by a licensed psychiatrist, or, if one is not readily available, by a physician.

Upon arrival to the facility for emergency examination and/or treatment, the person taken into custody must be examined by an emergency room [psychiatrist or] physician within two (2) hours of his/her arrival in order to determine whether the person is either severely mentally disturbed, or disabled and in need of immediate treatment. If the psychiatrist or physician determines that the person poses a danger of harm or injury to himself or others, and that he/she is in need of emergency treatment, the psychiatrist (or physician) must so certify by filing a written certification to that effect. V.I. Code Ann. tit. 19, § 722(c).

Only after the psychiatrist or physician has certified that the person to be committed poses a danger of physical harm or injury to himself and others, may the individual be detained at the

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Bluebook (online)
41 V.I. 57, 1999 WL 552769, 1999 V.I. LEXIS 19, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-k-d-virginislands-1999.