To avoid ludicrous results, interpretation of a civil commitment statute should facilitate the spirit and intent of the law without losing sight of the fact that a person's liberty is at risk, a Washington appellate court ruled.
Three individuals diagnosed with mental disorders challenged their involuntary detentions. In obtaining the orders of detention, a social worker had signed a petition for involuntary treatment. The statute under which the petition was filed required that the petition be signed by a physician, although none of the petitions had such a signature. The petitions were filed, followed soon after by a physician's affidavit. After probable cause hearings, the individuals were then ordered to undergo involuntary treatment.
The court held that even though civil commitment statutes must be strictly construed to protect individual liberty, they must not be so strictly construed that they result in absurd consequences. The court acknowledged the statute's physician signature requirement but went on to note that the physicians who examined the three individuals had all filed affidavits before the probable cause hearings. Failure to provide a physician's signature, the court stated, was a matter of form only. The court noted that the appellants had suffered no prejudice from the procedure with which they were committed.
WHAT A.S. MEANS
Failure to provide a physician's signature on a release petition is a matter of form only, despite a statutory requirement to the contrary. Petitions may be granted where a physician has filed an affidavit instead.
