In Matter of Linda M.,[1] the supreme court held that civil commitment proceedings to treat mental illness may be held sequentially or concurrently with criminal commitment proceedings to treat incompetency to stand trial.[2] Linda M. was found incompetent to stand trial for criminal charges and committed to Alaska Psychiatric Institute (API) for restoration of competency, but API was not given the authority to involuntary medicate Linda.[3] After determining medication was necessary and Linda would not accept it, API brought civil commitment proceedings to receive authorization to administer crisis medication.[4] Linda moved to dismiss the proceedings, arguing that the district court overseeing her criminal proceedings which first committed her should oversee these proceedings, not the superior court.[5] The supreme court affirmed the lower court’s decision to deny Linda’ motion to dismiss.[6] The court reasoned that a state may seek to involuntarily medicate a committed defendant for purposes other than those related to the defendant’s competency.[7] Competency for trial does not play a factor in determining whether a person may be civilly committed and forcing the two proceedings to run sequentially, rather than concurrently, may lead to a gap in the necessary authority to treat an individual.[8] Thus, civil commitment proceedings to treat mental illness may be held sequentially or concurrently with criminal commitment proceedings to treat incompetency to stand trial.
[1] 440 P.3d 168 (Alaska 2019).
[2] Id. At 172–73.
[3] Id at 169–70.
[4] Id. at 170.
[5] Id.
[6] Id. at 171.
[7] Id. at 172.
[8] Id. at 172–73.
