In the Matter of the Necessity for the Hospitalization of Carl S.

Summary

The Alaska Supreme Court vacated Carl S.’s 30-day civil commitment order. It declined to grant relief for an unpreserved deficiency in the petition’s signatures because Carl could not show prejudice, but held that committing him under an unpleaded theory of grave disability violated due process because he lacked notice and an opportunity to present additional evidence or cross-examination. The court also held that the commitment statutes and civil rules did not independently require the petition to identify the specific statutory definition of grave disability.