In the Matter of V.H., Alleged to be Seriously Mentally Impaired, V.H.

Summary

The court held that a respondent in an involuntary civil commitment proceeding under Iowa Code chapter 229 has no federal constitutional right to waive the statutorily required assistance of counsel and represent himself. The court rejected Sixth Amendment, substantive due process, and procedural due process theories, while holding that any state constitutional claim was not preserved. The court also held that substantial evidence supported the finding of a recent overt act demonstrating dangerousness and affirmed both challenged rulings.