In the Matter of the Hospitalization of April S.

Summary

The court affirmed the order authorizing April S.’s initial hospitalization for a 72-hour evaluation, holding that the ex parte procedure complied with due process even though April was not allowed to participate in the brief inquiry. It vacated the later 30-day commitment order because OCS was not a statutory “parent or guardian” authorized to admit a child voluntarily under the parental-admission statute, making April’s confinement involuntary from the outset and triggering the protections applicable to continued commitment. The court therefore did not reach April’s constitutional challenges to the parental-admission statute.