In the Matter of Mabel B., 485 P.3d 1018 (Alaska 2021), the supreme court held that the substantive due process rights of involuntarily committed mental health patients are violated when procedural delays to patients’ release or extended hospitalization are caused by understaffed mental health hospitalization facilities. (Id. at 1026). State law allows for involuntary commitment of individuals suffering from mental illnesses who are reasonably believed to present a likelihood of serious harm to self or others or are gravely disabled as a result of mental illness. (Id. at 1019). Committed individuals must receive a mental health evaluation within 24 hours of arriving at an evaluation facility, after which a mental health professional can petition for an ex parte order authorizing hospitalization for evaluation at certain designated facilities. (Id. at 1020). The designated facility has 72 hours after the patient’s arrival to evaluate the individual and either release the patient or petition for extended hospitalization. (Id.). There is no explicit statutory requirement regarding the amount of time that may pass between a facility receiving an ex parte order authorizing hospitalization and the facility completing the transfer of the committed individual to a designated facility. (Id.). Two women who were committed under state law were held without transfer to a designated facility for over two weeks. (Id. at 1020–23). Each petitioned for a review hearing to challenge their continued detention as a substantive due process violation. (Id. at 1023). The supreme court agreed and vacated orders from lower courts which had approved continued pre-transport detention at the evaluation facilities. (Id. at 1026). The supreme court determined that the State’s explanation for continued detention at the evaluation facility centered on problems arising from understaffed designated facilities. (Id.). The supreme court maintained that this did not satisfy the constitutional requirement of a reasonable relationship between the nature and duration of involuntary psychiatric commitment on the one hand, and the purpose for which an individual is committed on the other. (Id.). The supreme court thus held that the substantive due process rights of involuntarily committed mental health patients are violated when procedural delays to patients’ release or extended hospitalization are caused by understaffed mental health hospitalization facilities. (Id.).