In Re the Detention of S.P.

CourtCourt of Appeals of Washington
DecidedSeptember 17, 2024
Docket58760-2
StatusUnpublished

This text of In Re the Detention of S.P. (In Re the Detention of S.P.) 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 the Detention of S.P., (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

September 17, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Detention of: No. 58760-2-II

S.P., UNPUBLISHED OPINION Appellant.

LEE, J. — S.P. appeals the trial court’s order committing him to 90 days of involuntary

treatment. S.P. argues that there is insufficient evidence to support the jury’s finding that he is

gravely disabled. S.P. also argues that his due process rights were violated because the trial court

did not require the jurors to agree on the basis of its grave disability finding.1

Because S.P. displays severe deterioration from safe behavior, loss of cognitive and

volitional control, and an inability to provide for his own essential needs, we hold sufficient

evidence supported the jury’s finding that S.P. is gravely disabled. Further, because S.P. failed to

raise a due process argument at the proceedings below and he cannot show there was a manifest

error affecting a constitutional right, we decline to address S.P.’s due process argument.

Accordingly, we affirm the superior court’s commitment order.

1 S.P. references a 12-member jury, and argues 10 out of 12 jurors needed to agree in order to have a valid verdict throughout his brief. S.P.’s jury trial, however, consisted of a 6-member jury, which only requires 5 out of the 6 jurors to agree on a verdict. RCW 4.44.380. Accordingly, we interpret S.P.’s argument to be that due process requires the jurors who found him gravely disabled to agree on the basis for the gravely disabled finding, and not an argument that a jury of fewer than 12 violates due process in an involuntary commitment trial. No. 58760-2-II

FACTS

A. BACKGROUND

In February 2023, S.P. was arrested and charged with third degree malicious mischief.

Based on behaviors S.P. was exhibiting, S.P. was referred for a mental health evaluation.

In March 2023, a designated crisis responder (DCR) evaluated S.P. and found that S.P.

presented as “gravely disabled and in danger of serious harm resulting from a failure to meet [his]

health and safety needs,” as evidenced by S.P.’s disorientation, delusions, and inability to

distinguish between delusions and reality. Clerk’s Papers (CP) at 4 (underlining omitted). The

DCR also noted that S.P. had previous admissions to Western State Hospital in 2008 and 2018,

along with “a history of incarceration, history of violence towards others to include charging at

family with a knife, history of psychiatric hospitalization dating back to at least 2008, and history

of nonadherence to psychiatric medications.” CP at 3 (underlining omitted). S.P. was diagnosed

in 2009 with schizotypal personality disorder and paranoid schizophrenia. The DCR filed an

emergency detention petition.

Once the DCR determined that S.P. met the criteria for involuntary detention, S.P. was

taken to a hospital where he was medically cleared. S.P. was then admitted to Telecare Thurston

Mason Evaluation and Treatment Center (Telecare) on March 11, with a probable cause hearing

set for March 16. While at Telecare, S.P. experienced numerous delusions, responded to internal

stimuli, was disorganized, had loose associations, spoke with pressured speech, and was unable to

reason a decision.

2 No. 58760-2-II

At the March 16 probable cause hearing, the superior court found S.P. gravely disabled as

a result of a behavioral health disorder and in danger of serious physical harm resulting from failure

to provide for his essential needs. S.P. was committed to 14 days of involuntary treatment.

B. 90-DAY PETITION

In late March 2023, Justina Harris-McCray, a mental health professional, and Brenda

Alexander-O’Neil, a psychiatric nurse practitioner, filed a 90-day involuntary treatment petition.

In April 2023, two new petitioners filed a 90-day involuntary treatment petition. The petition was

substantively the same as the March 90-day petition; the only difference was a substitution of

petitioner-providers, now Kyle Schaeffer, a mental health professional, and Stephanie Brooks, a

psychiatric nurse practitioner.

According to the petition, S.P. needed further treatment because he continued to be gravely

disabled due to a “failure to provide for [his] essential human needs” and because S.P. displayed

“severe deterioration in routine functioning.” CP at 32, 34 (boldface omitted). Since his admission

to Telecare, S.P. presented as “disheveled, disorganized, delusional, tangential and irritable”

shown through different interactions such as “yell[ing] at the provider,” “responding to internal

stimuli,” and “making nonsensical statements about the country not following God’s will.” CP at

33. S.P. also expressed intentions to involve the FBI because he was “losing muscle, being starved

and [because] drugs [were] being forced upon him.” CP at 33. S.P. then lost his phone privileges

after calling 911 multiple times to report his delusions. S.P. later requested that a provider from

Telecare call the FBI for him and express to the FBI that S.P. was “‘being poisoned and starved.’”

CP at 34. The petition further explained:

3 No. 58760-2-II

[S.P.] has a mental disorder that has substantial adverse effects upon [S.P.]’s cognitive or volitional functions in the following ways: [S.P.] has a history of impatient hospitalizations. . . history of involuntary detentions. . . [and] history of illegal behavior. . . . [S.P.] often believes that psychiatric medication is going to kill him. He has a history of disorganization, confusion, tangential and loose associations, hyperverbal and pressured speech, grandiose and persecutory delusions, and can be observed responding to internal stimuli.

CP at 76 (underlining omitted).

S.P. also told providers at Telecare that he had written a book, worked for a healthcare

company, that he owned his own banking system, and that he owned “‘seven deeds of land.’” CP

at 79. S.P. also made statements to providers such as, “[T]he provider was being sentenced to the

‘death penalty and 38,000 of . . . incurable diseases,’” and “‘I’m not taking pills! You’re giving

me pills instead of food. That’s a violation of my civil liberties. The judge told me I was free to

go.’” CP at 80. On another occasion, S.P. “pushed the door shut on the RN and would not allow

her into the room with the computer . . . . He allowed the RN to enter about 2 minutes later.” CP

at 32. S.P. then slammed the laptop computer shut and attempted to throw it in response to

suggestions to take medication. Additionally, S.P. did not sleep, isolated himself, only came out

of his room for meals, and “had not showered for four days.” CP at 82.

C. JURY TRIAL

S.P. requested a jury trial. The trial court empaneled a six-member jury. Schaeffer,

Brooks, and S.P. testified.

1. Schaeffer’s Testimony

Schaeffer testified that he is a clinician at Telecare. Schaeffer noted that he first met S.P.

on March 11, 2023, when S.P. was admitted to Telecare. Schaeffer testified that he diagnosed S.P.

with schizophrenia based on S.P.’s presentation of several symptoms, including delusions,

4 No. 58760-2-II

hallucinations, disorganized thought, and “poverty of speech,” meaning S.P. “struggle[d] to come

up with words and speak his mind clearly.” Verbatim Rep. of Proc.

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