In In re Hospitalization of Luciano G., the supreme court held the evidence in an involuntary commitment order sufficiently supported a finding that the detainee was likely to cause harm to himself or others. After becoming belligerent with an airport ticketing agent, Luciano G. balled his fists and refused to cooperate with an airport security agent. Airport police also found Luciano had unlocked bags with him that contained multiple guns, many of which were loaded, in violation of regulations. A psychiatrist at Alaska Psychiatric Institute (API) also testified that after being involuntarily committed, Luciano would make intense, intimidating stares at him during their sessions. A magistrate found Luciano threatening and likely to cause harm to others, and the superior court affirmed those factual findings and signed a 30-day commitment order. On appeal, Luciano argued he was not likely to cause harm to others because he had not assaulted anyone or made verbal threats. The supreme court affirmed the commitment order holding the superior court’s finding that Luciano was likely to cause harm to himself or others was supported by clear and convincing evidence. The court reasoned that threatening harm could include threatening nonverbal actions based on the plain language of the statute and common usage of the word “threat.” The court then noted the incident at the airport with the unlocked guns and balled fists as well as the menacing stares at API all supported the finding that Luciano was a threat to himself or others. Affirming the lower court, the supreme court held the evidence in the involuntary commitment order sufficiently supported a finding that the detainee was likely to cause harm to himself or others.
 450 P.3d 1258 (Alaska 2019).