In the Matter of the Necessity for the Hospitalization of Mark v.

Summary

The Alaska Supreme Court dismissed Mark V.'s appeal as moot because his 30-day involuntary commitment had expired and the collateral-consequences exception did not apply. Mark's multiple recent prior commitment orders, the absence of any procedural or fundamental flaw, and the lack of any showing of additional consequences from the challenged order made substantive review unwarranted. The court also held that the statutory right to appeal did not supersede mootness and declined to vacate the expired commitment order. Stowers, J., joined by Maassen, J., dissented, arguing that involuntary commitment appeals should be reviewed on the merits or governed by a rebuttable presumption of collateral consequences.