HEALTH LAW
Supreme Court of Alaska (2024)
Erik Gordon
In In the Matter of Kara K., 555 P.3d 26 (Alaska 2024) the supreme court held that the statutory definition of “mental illness” encompasses psychosis resulting from lupus and that the definition does not violate a patient’s right to due process. (Id. at 37–38). Alaska Psychiatric Institute (API) sought a 30-day involuntary commitment order for Kara K. on the basis of her psychosis, which may have arisen from lupus. (Id. at 32). The standing master found by clear and convincing evidence that Kara K. was mentally ill, noting that the cause of the illness was inconsequential. (Id. at 34). The superior court agreed with the master and granted the order. (Id.). Kara K. appealed and argued that the statutory definition of mental illness should exclude mental or emotional impairments that may arise from an “underlying physical medical condition” (i.e., lupus). (Id. at 35). She argued in the alternative that due process requires courts to conclusively determine that a physical condition is not the cause of the mental illness before ordering involuntary commitment. (Id.). The supreme court affirmed the superior court’s decision, reasoning that neither the text nor the legislative history of the statute at issue supported Kara K.’s construction of the statute. (Id. at 36–37). Moreover, the supreme court articulated that neither a narrow construction nor an extra requirement to supplement the statute was required to guard against infringements on liberty interests, and thus, due process is not implicated by the definition. (Id. at 38). Affirming the lower court’s decision, the supreme court held that the statutory definition of “mental illness” encompasses psychosis resulting from lupus and that the definition does not violate due process. (Id. at 37–38).
