In the Matter of the Necessity for the Hospitalization of Arthur J.

CourtAlaska Supreme Court
DecidedFebruary 5, 2025
DocketS18785
StatusUnpublished

This text of In the Matter of the Necessity for the Hospitalization of Arthur J. (In the Matter of the Necessity for the Hospitalization of Arthur J.) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Necessity for the Hospitalization of Arthur J., (Ala. 2025).

Opinion

NOTICE Memorandum decisions of this court do not create legal precedent. A party wishing to cite such a decision in a brief or at oral argument should review Alaska Appellate Rule 214(d).

THE SUPREME COURT OF THE STATE OF ALASKA

In the Matter of the Necessity for the ) Hospitalization of ) Supreme Court No. S-18785 ) ARTHUR J. ) Superior Court No. 3AN-23-01169 PR ) ) MEMORANDUM OPINION ) AND JUDGMENT* ) ) No. 2072 – February 5, 2025 )

Appeal from the Superior Court of the State of Alaska, Third Judicial District, Anchorage, William F. Morse, Judge.

Appearances: Courtney R. Lewis, Anchorage, for Arthur J. Laura Wolff, Assistant Attorney General, Anchorage, and Treg Taylor, Attorney General, Juneau, for the State of Alaska.

Before: Maassen, Chief Justice, and Carney, Borghesan, Henderson, and Pate, Justices.

INTRODUCTION A man appeals the superior court’s order committing him for mental health treatment. He argues that the State failed to prove that he posed a risk of harm to himself and that no less restrictive alternative to involuntary commitment was available.

* Entered under Alaska Appellate Rule 214. Because we conclude that the evidence supported a finding that he was gravely disabled, we need not determine whether he also was likely to harm himself. We therefore affirm the commitment order on the basis that he was gravely disabled. And because the superior court specifically found that the man’s testimony about his proposed alternative to commitment was not credible, we affirm the court’s finding that there was no less restrictive alternative to commitment. FACTS AND PROCEEDINGS Arthur J.1 was voluntarily admitted to the Alaska Psychiatric Institute (API) in May 2023. A week later API staff petitioned the superior court for an order authorizing his continued hospitalization for evaluation. The court granted the petition. Several days later API staff petitioned the court for an order authorizing Arthur’s 30- day commitment. The petition alleged that Arthur was likely to cause serious harm to himself and that he was gravely disabled because his severe delusions caused him to refuse necessary medical treatment. The superior court held a hearing on the petition. The State called Arthur’s treating psychologist and nurse practitioner as witnesses. The psychologist testified that she believed Arthur suffered from delusional disorder, a form of psychosis in which a person endorses “very unusual beliefs” that other people would not ordinarily believe to be true. She explained that people with this condition are unable to accept evidence contrary to their delusional beliefs, which prevents them from understanding their beliefs are not grounded in reality. She stated that Arthur believed that his mother, with whom he lived before his hospitalization, had abducted him as an infant from his birth mother. The psychologist also testified that Arthur had been diagnosed with human immunodeficiency virus (HIV) and syphilis while he was at API. She testified

1 We use a pseudonym to protect the respondent’s privacy. -2- 2072 that Arthur was refusing treatment for those conditions because he did not believe he had either of them, and he refused further testing at Providence Hospital to confirm the diagnoses. She stated that she believed his distrust of medical providers was due to his delusional beliefs, as was his refusal to seek treatment for HIV and syphilis. The psychologist testified that Arthur’s top priority after his release from API was to go to government agencies to acquire information about his alleged abduction, and not to seek medical treatment. She also testified that she believed Arthur could inadvertently be a danger to himself and would suffer continued psychological distress without treatment for his delusional disorder. Finally, the psychologist testified that no less restrictive alternative than commitment to API could adequately serve Arthur’s treatment needs. A nurse practitioner who treated Arthur also testified, describing Arthur’s beliefs about his upbringing and abduction from his “real” family. The nurse practitioner testified that Arthur’s thought processes had become increasingly delusional since his admission to API. As an example he referred to Arthur’s belief that a public health worker who came to API to conduct contact tracing after his HIV diagnosis was actually part of a group called “Blackface,” and had come in and out of his life in recent years. The nurse practitioner stated that it was clear to him that Arthur had never met the worker before she arrived at API. The nurse practitioner also testified that Arthur was likely to be a danger to himself because he refused treatment for syphilis and HIV, even though syphilis is easily treated and HIV can be effectively managed. The nurse practitioner acknowledged that he did not believe Arthur would be at risk of harming himself if he had not been diagnosed with those conditions. He differentiated Arthur’s situation from a person who knowingly refused medical treatment despite accepting the fact of the diagnosis as true. The nurse practitioner described Arthur’s HIV and syphilis diagnoses as “not real to him.” He was also concerned that Arthur’s delusional disorder was

-3- 2072 worsening because he had incorporated people he met at API into his delusions, which the nurse practitioner believed would continue to worsen if Arthur did not receive treatment. He testified that without a court order Arthur had not been taking medication and API had not been able to treat Arthur’s delusions. The nurse practitioner testified that there was no less restrictive alternative to commitment because Arthur had refused to consider any of the “numerous different alternatives in terms of both medical and mental health treatment” that API had recommended. And he testified Arthur had indicated he would not return to his mother’s home if he was released from API. Arthur testified after API’s witnesses. He described reading a book given to him by a stranger that featured an Alabama court decision about an abducted child. He said it prompted him to research his own background, and he believed that he could be the abducted child. Arthur testified that the abducted child was born with a club foot, and that while he did not know if he was born with a club foot, he thought it was a possibility because his feet were two different sizes. Arthur testified that different sized feet can result when a club foot “grow[s] into a normal foot.” Arthur testified that he had spoken with his mother and agreed that he would return to her home after he was released, and they would research medical providers together. Arthur stated he would look for medical care outside of API or Providence Hospital because he believed those facilities discriminated against him based on his race and sexual orientation. He also stated he had reservations about those hospitals because of inconsistent test results,2 and going “weeks” without getting results he was told he would receive the same day.

2 Arthur was apparently initially told that he did not test positive for HIV or syphilis, but additional testing showed positive results. -4- 2072 The superior court made oral and written findings and committed Arthur to API for up to 30 days. The court found by clear and convincing evidence that Arthur was mentally ill. It reasoned that there was no evidence that Arthur was actually abducted as a child, and it was not a rational conclusion to draw from the story about an abducted child in Alabama.

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Related

Wetherhorn v. Alaska Psychiatric Institute
156 P.3d 371 (Alaska Supreme Court, 2007)
In Re the Necessity for the Hospitalization of Stephen O.
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