In the Matter of the Detention of G.D., Appellant.
appeals the trial court's 14-day involuntary commitment
order, arguing the findings of fact are insufficient. After
G.D. filed a notice of appeal, the trial court entered
specific detailed findings of fact to supplement the general
"boilerplate" findings entered at the completion of
the commitment hearing. We grant G.D.'s motion to strike
the supplemental findings because the State failed to give
notice to appellate counsel and failed to comply with RAP
7.2. Because the initial boilerplate findings are
insufficient to permit meaningful review, we reverse.
4, 2018, G.D. went to Virginia Mason Hospital in Seattle. She
was convinced radio frequency identification chips had been
implanted in her body. She asserted that she would remove the
chips herself if she did not receive medical help. A
designated medical health professional petitioned to detain
G.D. for 14 days of involuntary mental health treatment.
court held a probable cause hearing on June 6, 2018. The
court determined G.D. presented a likelihood of serious harm
to herself. The court entered boilerplate findings of fact on
the same day.
22, 2018, G.D. filed a notice of appeal. And on September 7,
2018, the trial court entered supplemental findings of fact
and conclusions of law.
moves to strike the September 7 supplemental findings of fact
and contends the June 6 findings are not sufficiently
specific to permit meaningful review.
At the conclusion of the [probable cause] hearing, the court
shall make written findings of fact and conclusions of law,
and enter an order for release or for detention for an
additional 14 days in an evaluation and treatment facility,
or such lesser treatment as shall to the court appear proper.
where findings are required, they must be sufficiently
specific to permit meaningful review." To be
sufficiently specific, the findings should indicate the facts
which support the conclusions.
In re Detention of LaBelle, our Supreme Court
considered the following boilerplate findings in an
involuntary commitment order: "The Court finds by clear,
cogent, and convincing evidence that:. .. (c) The respondent
is gravely disabled." The court decided, "[T]he
written findings here are not sufficiently specific to permit
meaningful review. The language used is standardized and of
necessity very general. The findings do not indicate the
factual bases for the trial court's ultimate conclusion
of grave disability.
on June 6, 2018, the same day as the commitment hearing, the
court entered the following check-the-box findings:
[X] RCW 71.05.240 Probable Cause Hearing. Petitioner
has proven the following by a ...