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In re Detention of G.D.

Court of Appeals of Washington, Division 1

October 28, 2019

In the Matter of the Detention of G.D., Appellant.

          Verellen, J.

         G.D. 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.

         FACTS

         On June 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.

         The 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.

         On June 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.

         ANALYSIS

         G.D. moves to strike the September 7 supplemental findings of fact and contends the June 6 findings are not sufficiently specific to permit meaningful review.

         MPR 2.4(4) provides:

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.

         "Generally, where findings are required, they must be sufficiently specific to permit meaningful review."[1] To be sufficiently specific, the findings should indicate the facts which support the conclusions.[2]

         In 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."[3] 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.[4]

         Here, 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 ...

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