In Re The Detention Of A.O.

• Court: Court of Appeals of Washington
• Decided: July 17, 2023
• Docket: 84670-1
• Status: Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

IN THE MATTER OF THE DETENTION OF: No. 84670-1-I

A.O., DIVISION ONE

Petitioner. UNPUBLISHED OPINION

FELDMAN, J. — After a bench trial, the court concluded that A.O. presented a

likelihood of serious harm to others and was gravely disabled and involuntarily committed

her for 14 days. A.O. asserts that she had a constitutional right to have a jury determine

whether she had a mental illness justifying a 14-day involuntary commitment. We

disagree.

This court rejected A.O.’s argument in In re Detention of S.E., 199 Wn. App. 609,

611, 400 P.3d 1271 (2017). We confirmed S.E.’s holding that there is no right to a jury

trial in a hearing on a 14-day involuntary commitment petition in In re Detention of T.C.,

11 Wn. App. 2d 51, 59-60, 450 P.3d 1230 (2019).

A.O. argues that S.E. erred in its analysis of whether an individual is

constitutionally entitled to a jury trial under article I, section 21 of the Washington No. 84670-1-I/2

Constitution. See S.E., 199 Wn. App. at 614-15. Because A.O. advances no novel theory

as to why our analysis in S.E. is incorrect, we decline to overrule its holding.

Affirmed.

WE CONCUR: