State v. Mata

CourtNew Mexico Court of Appeals
DecidedDecember 19, 2024
StatusUnpublished

This text of State v. Mata (State v. Mata) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Mata, (N.M. Ct. App. 2024).

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number:__________

3 Filing Date: December 19, 2024

4 No. A-1-CA-41992

5 IN THE MATTER OF ISAAC MATA, 6 a person alleged to be in need of 7 mental healthcare.

8 STATE OF NEW MEXICO,

9 Petitioner-Appellee,

10 v.

11 ISAAC MATA,

12 Respondent-Appellant.

13 APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY 14 Robert Lara, District Court Judge

15 Raúl Torrez, Attorney General 16 Santa Fe, NM 17 Lawrence M. Marcus, Assistant Solicitor General 18 Justin Lauriano, Honors Attorney 19 Albuquerque, NM

20 for Appellee

21 Elliot A. Mohler 22 Las Cruces, NM

23 for Appellant 1 OPINION

2 YOHALEM, Judge.

3 {1} Respondent Isaac Mata appeals his involuntary commitment for a period not

4 to exceed thirty days under the provisions of the Mental Health and Developmental

5 Disabilities Code (the Code), NMSA 1978, §§ 43-1-1 to -25 (1976, as amended

6 through 2024). We affirm.

7 BACKGROUND

8 {2} Respondent was admitted to Memorial Medical Hospital (Memorial) in Las

9 Cruces, New Mexico on March 29, 2024, after he attempted suicide by burning down

10 his trailer while he was inside it. On April 16, 2024, the State filed a petition in

11 district court to commit Respondent to the New Mexico Behavioral Health Institute

12 for thirty days. The petition was supported by the affidavit of Hector Perez, a

13 psychiatric nurse practitioner, who testified that he was employed as the primary

14 psychiatric provider at Memorial, was involved in Respondent’s admission, and that

15 he had been Respondent’s primary treating physician since his admission.

16 {3} Perez’s affidavit was attached to the petition to the district court seeking a

17 thirty-day commitment. The affidavit served as the initial screening report required

18 by Section 43-1-11(A). Section 43-1-11(A) requires, in relevant part, that an initial

19 screening report be prepared “by the evaluating physician individually or with the

20 assistance of a mental health professional or, if a physician is not available, by a 1 mental health professional acceptable to the court,” and that the report be submitted

2 with the petition.

3 {4} Respondent contested the commitment. At the start of the hearing,

4 Respondent’s counsel objected to proceeding without a showing by the State that a

5 physician was not available at Memorial to prepare the initial screening report.

6 Respondent argued that without such a showing, the phrase in Section 43-1-11(A),

7 “if a physician is not available,” would be superfluous. When the district court asked

8 what would happen to his client if no such showing were made by the State, counsel

9 responded that his client would have to be released. Stating that it was relying on the

10 language of the commitment statute as a whole, the district court found that the

11 Legislature intended for it to be the responsibility of the evaluating facility to apply

12 to the court if they believed a commitment was needed and “there was not a

13 physician available for some reason.” Concluding that the preparation of the report

14 by a nurse practitioner, rather than a physician was not “a fatal flaw,” the court

15 proceeded with the hearing.

16 {5} Perez was sworn as the State’s only witness. Perez testified that he is a nurse

17 practitioner, and that he is the primary provider of psychiatric services at Memorial.1

We note that since Section 43-1-11(A) was enacted in 1977, the Legislature 1

has since provided for the licensing of nurse practitioners, see NMSA 1978, § 61-3- 23.2(E) (2014, amended 2022), and has permitted them to practice independently, see § 61-3-23.2(B)(2) (2014). In 2024, the Legislature required that hospitals and other health facilities give nurse practitioners parity with physicians in credentialing

2 1 The State asserted that Perez was “acceptable as an evaluator and a treating

2 physician” in preparing the screening report, and the district court found that Perez

3 is qualified to testify. See § 43-1-11(A).

4 {6} Respondent neither cross-examined Perez nor called a mental health expert of

5 his own, as the Code permits. See § 43-1-11(B). At the conclusion of the testimony,

6 Respondent’s counsel challenged the sufficiency of the evidence to establish that his

7 client was likely to benefit from the proposed treatment, and that a thirty-day

8 commitment was consistent with the least drastic means principle, two of the three

9 findings necessary for an order of commitment. See § 43-1-11(E). The evidence

10 supporting the third required finding, that Respondent was a danger to himself or

11 others, was not challenged.

12 {7} The district court found that unrefuted testimony established Respondent’s

13 high level of risk of harm both to himself and others, Respondent’s need for

14 treatment and a likelihood that he would benefit from treatment, and that

15 Respondent’s commitment for thirty days was consistent with the least drastic means

16 principle. The district court ordered Respondent involuntarily committed for

17 evaluation and treatment for no more than thirty days. Respondent timely appealed.

to serve on the medical staff. See § 24A-1-13(B) (2024). Although we note these changes in the law subsequent to the enactment of the Code provision at issue, to resolve this case, we need not, and, therefore, do not, decide whether a psychiatric nurse practitioner should be treated in all cases as equivalent to a physician under the Code.

3 1 DISCUSSION

2 I. The District Court Was Permitted to Accept the Screening Report and 3 Testimony of a Psychiatric Nurse Practitioner Without Evidence 4 Documenting the Unavailability of a Physician

5 {8} First, Respondent claims that evidence establishing that there was no

6 physician available at Memorial to prepare the screening report is necessary to

7 support the order of commitment, and, that in the absence of such evidence, the

8 commitment must be vacated and Respondent released. We do not agree.

9 {9} Respondent’s argument raises a question of statutory interpretation.

10 Respondent’s argument focuses on a single phrase in Section 43-1-11(A). That

11 section states as follows:

12 A. Every adult client involuntarily admitted to an evaluation 13 facility pursuant to Section 43-1-10 . . . has the right to a hearing within 14 seven days of admission unless waived after consultation with counsel. 15 If a physician or evaluation facility decides to seek commitment of the 16 client for evaluation and treatment, a petition shall be filed with the 17 court within five days of admission requesting the commitment. The 18 petition shall include a description of the specific behavior or symptoms 19 of the client that evidence a likelihood of serious harm to the client or 20 others and shall include an initial screening report by the evaluating 21 physician individually or with the assistance of a mental health 22 professional or, if a physician is not available, by a mental health 23 professional acceptable to the court.

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State v. Mata, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mata-nmctapp-2024.