In re Necessity for the Hospitalization of Rabi R.
In In re Necessity for the Hospitalization of Rabi R., 468 P.3d 721 (Alaska 2020), the supreme court held that the lower court’s failure to order a screening investigation upon receipt of a petition for involuntary detention for psychiatric evaluation was harmless error because the later proceedings presented sufficient evidence to support the detention. (Id. at 726–27). A man who had been previously diagnosed with schizophrenia sought treatment at a hospital for sunburns, and the hospital filed a petition for detention because the man was covered in vomit, sunburns, open sores on his inner thighs, and feces. (Id. at 727). The superior court granted this petition based on the hospital’s allegations without ordering a screening. (Id.). After commitment hearings, the standing master granted a petition for involuntary medication and recommended the man be committed for thirty days. (Id. at 729). Upon review, the superior court found clear and convincing evidence that the man was not fully aware of his condition and would not be able to care for himself in a socially acceptable manner, so commitment was the least restrictive means of treatment. (Id. at 729–30). On appeal, the man argued that the court initially erred by failing to order a screening investigation and by allowing consideration of some facts present in the petition but not entered into evidence. (Id. at 731–32). The supreme court affirmed the lower court’s decision, reasoning that while these were errors they were harmless because the overall record and proceedings supported the finding that detention, commitment, and medication were in the man’s best interests. (Id. at 727). The court further explained that any evaluations conducted before the filing of a petition for involuntary detention cannot satisfy the requirement for a screening investigation. (Id. at 731). Affirming the lower court’s decision, the supreme court held that the errors were harmless and that the court did not err in granting the detention, commitment, and medication orders. (Id. at 727).