State v. Warner

CourtSuperior Court of Delaware
DecidedFebruary 27, 2025
Docket20I-01948
StatusPublished

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

Bluebook
State v. Warner, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT FOR THE STATE OF DELAWARE IN AND FOR NEW CASTLE COUNTY

STATE OF DELAWARE, : : Case No. 20I-01948 : v. : : RANDY WARNER, : : Respondent. : :

Submitted: February 24, 20251 Decision: February 27, 2025

ORDER UPON APPEAL OF COMMISSIONERS’ ORDERS

Randy Warner2 (“Respondent”) filed a series of pro se letters

appealing this Court’s Commissioners’ Orders entered November 6, 20243

and February 12, 2025 (“Commissioners’ Orders”) in ongoing involuntary

commitment proceedings conducted pursuant to 16 Del. C. Chapter 50. For

1 This appeal considers claims raised in Respondent’s letters to this Court of November 6, 2024, November 7, 2024, November 8, 2024, January 21, 2025, January 31, 2025, February 3, 2025, February 5, 2025, February 6, 2025, February 10, 2025, February 12, 2025, February 17, 2025, and February 24, 2025. 2 This name has been assigned to Respondent due to the confidentiality of these proceedings. 3 The November 6, 2024 Order became moot when it expired; however, because Respondent sought consolidation of his appeals and both appeals raise the same legal issues, they are discussed herein. the reasons set forth herein, Respondent’s appeals are denied and the

Commissioner’s Orders are AFFIRMED.

RELEVANT FACTS AND PROCEDURAL HISTORY

When a patient meets the criteria for an involuntary psychiatric

commitment,4 the court enters an order which cannot exceed 3 months in

duration (“90-day commitment order”).5 Upon expiration of the 90-day

commitment order, the court must convene a subsequent hearing, every 3

months, to review whether “continued involuntary inpatient treatment is

necessary”6 and, if warranted, issue another 90-day commitment order.

4 Those criteria under16 Del. C. § 5011(a) are:

(1) The individual is a person with a mental condition; (2) Based upon manifest indications, the individual is: a. Dangerous to self; or b. Dangerous to others; (3) All less restrictive alternatives have been considered and determined to be clinically inappropriate at the time of the hearing; and (4) The individual has declined voluntarily inpatient treatment, or lacks the capacity to knowingly and voluntarily consent to inpatient treatment. When evaluating capacity, the court shall consider an individual’s ability to understand the significant consequences, benefits, risks, and alternatives that result from the individual’s decision to voluntarily request or decline inpatient treatment.

5 16 Del. C. § 5011(c). 6 16 Del. C. § 5011(d).

2 Respondent has an extensive history of civil involuntary psychiatric

commitments.7 During a February 22, 2024 involuntary commitment

hearing, the Commissioner denied Respondent’s request for an independent

psychiatric examination, at the State’s expense, reasoning:

[T]here have been 29 previous [90-day commitment] orders where doctors testified. Only two doctors…were not adamant that [Respondent] did not have an illness with psychosis as an element. All the other doctors consistently diagnosed him with a mental illness where psychosis was exhibited.8

Respondent does not acknowledge his psychiatric diagnoses9 or concomitant

symptoms and actions that make him a danger to himself and others.

Respondent refuses medications while inpatient10 and has not been

compliant with his outpatient treatment.11

Respondent now appeals the Commissioners’ Orders of November 6,

2024 and February 12, 2025 on two discrete issues. First, Respondent

argues the Commissioners erred by denying his request for an independent

7 See State v. Randy Warner, C.A. No. 20I-01948 (Del. Super. June 18, 2024)(Denying appeal). 8 Warner, C.A. No. 20I-01948 at 14 (cleaned up). 9 Id.at 14, 17-18. 10 Id.at 18. 11 Id.at 17-18.

3 psychiatric examination.12 Second, Respondent argues the Commissioners

failed to grant his requests for court-appointed counsel of his own

choosing.13

STANDARD OF REVIEW

The standard applicable this Court’s review of Commissioners’

Orders in involuntary psychiatric commitment proceedings is well-

articulated in State v. Randy Warner:14

Superior Court Civil Rule 132(a)(4) provides [its] commissioner the power to conduct case- dispositive hearings including, among other things, mental hearings pursuant to …16 Del. C. ch. 50.15 Upon review of a case-dispositive determination, the Court shall make a “de novo determination of those portions of the report or specified proposed findings of fact or recommendations made by the Commissioner.”16

The remainder of Rule 132(a)(4)(iv) of the Superior Court Civil Rules

(“Rules”) permits this Court to “accept, reject, or modify, in whole or in

part, the findings or recommendations made by the Commissioner, receive

12 See Respondent’s Letters dated November 6, 2024 and February 12, 2025. 13 See Respondent’s Letter dated November 7, 2024. 14 Warner, C.A. No. 20I-01948 at *1-2 (quoting Smith v. State, 2019 WL 3231201 (Del. Super. July 17, 2019)). 15 Super. Ct. Civ. R. 132(a)(4), (4)(iv). 16 Warner, C.A. No. 20I-01948 at *1-2.

4 further evidence, or recommit the matter to the Commissioner with

instructions.” 17 Respondent’s due process claims are questions of law, so

the Court reviewed the Commissioners’ Orders de novo.

DISCUSSION

I. The Commissioners Did Not Err by Denying Respondent’s Requests for Independent Reviews.

Respondent argues the Commissioners erred by refusing his request to

court-appoint Dr. Jose Caprio to perform an independent psychiatric review

because 16 Del. C. §5007(3) does not limit the number of independent

reviews.18 Respondent further claims Dr. Caprio, an employee of the

Delaware Psychiatric Center, could perform the review at no charge.19

16 Del. C. §5007 states that an independent psychiatric review is a

procedural right; however, the statute does not specify the number of

independent reviews to which an indigent patient is entitled:

When a designated treatment facility, hospital or outpatient treatment provider seeks to require an individual to be involuntarily hospitalized pursuant to … an involuntary inpatient commitment hearing … without the individual’s consent, the individual shall be entitled: ... 17 Rule 132(a)(4)(iv) (cleaned up). 18 See Respondent’s letter to the Court, dated November 12, 2024, at *2. 19 Whether Dr. Caprio is willing to perform the exam free of charge is disputed.

5 (3) To be represented by counsel at all judicial proceedings, such counsel to be court-appointed if the individual cannot afford to retain counsel; and to be examined by an independent psychiatrist or other qualified medical expert and to have such psychiatrist or other expert testify as a witness on the individual’s behalf, such witness to be court appointed if the involuntary patient cannot afford to retain such witness.20 Although the statute is silent, Respondent has repeatedly raised (and this

Court has decided) the issue of whether Section 5007(3) entitles Respondent

to multiple independent reviews at the State’s expense.21 As summarized in

this Court’s June 18, 2024 Order22 denying Respondent’s 2024 appeal this

Court held:

The file shows that Respondent constantly demands that a person other than the treating psychiatrist examine him. The statute allows for an independent examination. Respondent was granted such twice. The statute does not require an examination for each hearing or every time Respondent requests it. It just allows for an independent examination of Respondent and Respondent received an independent examination. He has had his independent examination as statutorily required and he is not entitled to another.23

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

Related

United States v. Gonzalez-Lopez
548 U.S. 140 (Supreme Court, 2006)
RADULSKI FOR TAYLOR v. Delaware State Hosp.
541 A.2d 562 (Supreme Court of Delaware, 1988)
Bultron v. State
897 A.2d 758 (Supreme Court of Delaware, 2006)
Gannett Co., Inc. v. Kanaga
750 A.2d 1174 (Supreme Court of Delaware, 2000)
Bradley v. State
135 A.3d 748 (Supreme Court of Delaware, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Warner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-warner-delsuperct-2025.