Supreme Court of Alaska (2022)
In In re Jonas H., 513 P.3d 1019 (Alaska 2022), the supreme court held that the superior court must explicitly make or incorporate findings relevant to every contested Myers factor to grant an order for the involuntary administration of psychotropic medication. (Id. at 1026). Jonas’s schizophrenia began to worsen to the point his family feared he was unable to take care of himself. (Id.). The State motioned the superior court for orders authorizing the thirty-day involuntary commitment of Jonas and administration of psychotropic medication. (Id.). In the medication hearing, the State’s independent investigator stated that Jonas had reasonable objections (feeling side-effects) and unreasonable objections (being “spiritually threatened”) to his medication. (Id. at 1021–22). Jonas also testified that he preferred other treatment methods, including exercise, a good diet, and a lot of sunlight. (Id. at 1025). The superior court granted both of the State’s orders. (Id. at 1022). However, the court did not address Jonas’s objections to side-effects and alternative treatment in its order or on the record. (Id. at 1025). On appeal, Jonas argued that the superior court insufficiently addressed the Myers factors, all of which must be met for a court to order involuntary administration of psychotropic medication. (Id. at 1024). The supreme court found for Jonas, noting that the superior court had only addressed one of the five Myers factors, leaving the factors related to side-effects and alternative treatment unanswered. (Id. at 1025). While the supreme court agreed with the State that the superior court only needed to address contested factors, it concluded that the lower court had insufficiently addressed the three factors contested by Jonas. (Id. at 1025–26). Accordingly, the supreme court vacated the superior court’s order, holding that the superior court must explicitly address each contested Myers factor to grant an order for the involuntary administration of psychotropic medication. (Id. at 1026).