In In re Hospitalization of Danielle B.,[1] the supreme court found, upon review of an involuntary commitment petition, that sufficient evidence supported a finding that involuntary hospitalization was the least restrictive treatment option. When Danielle was evicted from a motel, she assaulted a police officer at the scene and then threatened to assault staff when she arrived at a hospital. During an involuntary commitment hearing, an Alaska Psychiatric Institute (API) psychiatrist testified that Danielle had schizoaffective disorder. He also testified that involuntary commitment was the least restrictive treatment option because Danielle’s history showed she would not do well in outpatient treatment. The special master and superior court both credited the psychiatrist’s testimony and discounted Danielle’s vague testimony that she could find an alternative outpatient treatment program, so the superior court ordered Danielle committed for up to 30 days. On appeal, Danielle argued the state did not show involuntary commitment was the least restrictive treatment option because the state did not prove community-based treatment options were inadequate to protect her and the public. The supreme court affirmed the commitment order holding the finding that involuntary commitment was the least restrictive treatment option was supported by sufficient evidence. The supreme court noted the API psychiatrist and Danielle both testified that she would not participate in the one outpatient treatment option both parties had identified. The supreme court also stated the special master and superior court both adequately weighed the testimony. Affirming the lower court, the supreme court held sufficient evidence supported a finding that involuntary hospitalization was the least restrictive treatment option.
[1] 453 P.3d 200 (Alaska 2019).
