In the Matter of the Necessity for the Hospitalization of Joan K.

Summary

The Alaska Supreme Court held that an appeal from a completed first involuntary commitment was reviewable under a collateral-consequences exception to mootness, without requiring a particularized showing of consequences. On the merits, it affirmed the commitment because clear and convincing evidence supported findings that Joan's mental illness caused a substantial risk of self-harm through illegal drug use and that no less restrictive placement would adequately address her needs. Justice Stowers, dissenting, would have dismissed or reached the merits differently by reversing for insufficient evidence and would have allowed every involuntary-commitment appeal despite expiration of the commitment.