In Re: M.A.C., Appeal of: M.A.C.

2024 Pa. Super. 95, 315 A.3d 163
Superior Court of Pennsylvania·Decided May 13, 2024·No. 373 WDA 2023·Published

Opinion

2024 PA Super 95

IN RE: M.A.C. : IN THE SUPERIOR COURT OF : PENNSYLVANIA

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APPEAL OF: M.A.C. :

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: No. 373 WDA 2023

Appeal from the Order Entered March 3, 2023 In the Court of Common Pleas of Butler County Civil Division at No(s):

MAD 2022-40326

BEFORE: BOWES, J., KUNSELMAN, J., and MURRAY, J. OPINION BY BOWES, J.: FILED: May 13, 2024 M.A.C. appeals the order denying his petition to expunge his involuntary mental health commitment pursuant to 50 P.S. § 7302 (“§ 302”) of the Mental Health Procedures Act (“MHPA”). We affirm.

On November 2, 2022, Appellant filed the underlying petition in accordance with 18 Pa.C.S. § 6111.1(g)(2), seeking both expunction of his § 302 commitment and restoration of his firearms rights.1 During the ensuing hearing, the trial court found the following facts, which are not in dispute:

[Appellant] was involuntarily committed pursuant to [a sixpart ] application for involuntary emergency examination and treatment on April 1, 2022. The application’s Part I was completed by Sgt. Donald Myers, Jr., which include[d] his observations and interactions of [Appellant]. His statement reads:

1 Since Appellant has not challenged the denial of his firearm rights, this appeal concerns only the denial of the portion of the petition requesting expungement of his commitment.

I was dispatched to the residence for persons inside residence. After checking exterior, then entrance, and finding nothing, it was found the subject hasn’t slept in three days and hearing voices. Subject had HDAD [sic] and very paranoid. House complete mess.

Doors and stairways barricaded with furniture.

Responded two hours later. Still hearing voices and suspect inside residence. After negotiating for [forty-

five] minute[s], finally made entry and once again found nothing. Kitchen area completely filthy with dirty dishes and pots over a week old. Found approximately [twenty] cases of water and ten to [fifteen] emergency meal buckets about the house.

Due to the individual barricading exits with furniture, the children, 7-year-old boy, 8-year-old girl, would not be able to exit residence. At one point[, the]

children were locked inside a bedroom closet. While [Children & Youth Services] caseworkers were speaking with [Appellant], the 7-year-old boy nearly knocked the couch onto himself.

When [Appellant] was taken from his residence for assessment and treatment, the two young children went into the care of Children & Youth Services. [Additionally, on Part I of the application, the sergeant checked a box indicating that he believed Appellant was severely mentally disabled and that treatment was necessary because he posed a clear and present danger to others.]

Alyssa Tomsey, D.O.[,] who stated her findings in Part VI of the application, examined [Appellant]. Her findings stated, “Paranoid” and “Auditory Hallucinations,” with “Inpatient management” being recommended as the treatment needed.

[Appellant] was committed for the maximum 120 hours. At the hearing the application came in as Plaintiff’s Exhibit 1.

Findings of Fact and Memorandum of Law, 6/7/23, at 1-2 (cleaned up).

On March 3, 2023, the trial court entered an order denying the petition to expunge and denying without prejudice the request for restoration of firearms rights. This timely appeal followed. The court ordered Appellant to

file a concise statement of errors pursuant to Pa.R.A.P. 1925(b), and Appellant complied. The court further entered findings of fact and a memorandum of law addressing the claims raised in the Rule 1925(b) statement.

Appellant presents the following three issues for our review:

1. Where th[e Pennsylvania Supreme] Court has held that “both a threat and an act in furtherance must be proven” under 50 P.S.

§ 7301(b)(1) in In re B.W., 250 A.3d 1163 (Pa. 2021), did the trial court err in finding that there was sufficient evidence to involuntarily commit Appellant where there were no findings of a threat and/or an act in furtherance to commit harm in either the application for involuntary emergency examination and treatment or the trial court’s opinion?

2. Where the trial court found that it was “not the role of the Court to second-guess a finding made by a physician that a [§] 302 commitment was medically necessary,” did the trial court err in failing to apply the proper standard of review articulated in In re Vencil, [152 A.3d 235 (Pa. 2017),] in finding that there was sufficient evidence to involuntarily commit Appellant?

3. Where this Court has held that the provisions of the [MHPA], 50 P.S. §§ 7101 et seq., be strictly followed in In re A.J.N., 144 A.3d 130 (Pa.Super. 2016), did the trial court err in failing to order the expungement of Appellant’s involuntary mental health commitment where the trial court found that “the Application was facially deficient”?

Appellant’s brief at 8 (cleaned up).

All of Appellant’s claims concern the trial court’s denial of his request for expunction made pursuant to § 6111.1(g)(2). Generally, we review the denial of such a petition for an abuse of discretion. See In re J.G.F., 295 A.3d 265, 269 (Pa.Super. 2023). However, “a challenge to the sufficiency of the evidence to support a 302 commitment presents a pure question of law,” and

therefore our standard of review is de novo. See In re Vencil, 152 A.3d at 246.

In pertinent part, § 6111.1(g)(2) provides as follows:

A person who is involuntarily committed pursuant to [§ 302] may petition the court to review the sufficiency of the evidence upon which the commitment was based. If the court determines that the evidence upon which the involuntary commitment was based was insufficient, the court shall order that the record of the commitment submitted to the Pennsylvania State Police be expunged.

18 Pa.C.S. § 6111.1(g)(2).

Our High Court has stated that in conducting such a review,

the plain language of [§] 6111.1(g)(2) directs a trial court to review the physician’s findings, made at the time of the commitment, to determine whether the evidence known by the physician at the time, as contained in the contemporaneouslycreated record, supports the conclusion that the individual required commitment under one (or more) of the specific, statutorily-defined circumstances.

In re Vencil, 152 A.3d at 242 (citation omitted). “[T]he appropriate standard of proof applicable to the physician’s record findings is a preponderance of the evidence standard.” Id. at 246. Further, this section requires “deference to the physician, as the original factfinder, as the physician examined and evaluated the individual in the first instance, was able to observe his or her demeanor, and has particularized training, knowledge[,] and experience regarding whether a [§] 302 commitment is medically necessary.” Id.

Our Supreme Court has recognized that by using the term of art “sufficiency of the evidence” within § 6111.1(g)(2), the legislature sought to

adopt the ideas associated with that precise meaning, including the fact that we review all reasonable inferences consistent with the doctor’s finding. Id. at 242-43 (noting that in other legal contexts, a “challenge to the sufficiency of the evidence . . . requir[es] review of fact of record in the light most favorable to the original decision-maker”); see also Commonwealth v Salinas, 307 A.3d 790, 793 (Pa.Super. 2023) (explaining that when reviewing the sufficiency of the evidence in the criminal context, we view the evidence “and all reasonable inferences derived therefrom” in the light most favorable to the verdict winner).

The Vencil Court also outlined the relevant portions of the MHPA thusly:

Free access — add to your briefcase to read the full text and ask questions with AI

In Re: M.A.C., Appeal of: M.A.C., 2024 Pa. Super. 95, 315 A.3d 163 (Pa. Ct. App. 2024).

2024 Pa. Super. 95 (In Re: M.A.C., Appeal of: M.A.C.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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