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

Summary

The court held that an appeal from a completed first involuntary commitment was reviewable under a newly adopted 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 protect her or the public. Justice Stowers, dissenting, would have dismissed neither the appeal nor the merits but would have reversed because the evidence was speculative and the State had not adequately explored less restrictive alternatives.