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IN RE: J.R. (2021)

Court of Appeals of North Carolina.2021-07-20No. No. COA20-457

Summary

Holding. The trial court's involuntary commitment order is affirmed.

J.R. appealed an order committing him to thirty days of inpatient mental health treatment. At his involuntary commitment hearing in Durham County, no attorney appeared on behalf of the state, although a doctor was present as a witness. J.R.'s counsel objected to proceeding without state representation, but the trial judge overruled the objection and conducted the hearing, calling the state's doctor as a witness and allowing J.R. to testify and cross-examine. The judge found J.R. mentally ill and dangerous to himself and ordered the commitment.

J.R. argued that the trial judge violated his right to an impartial tribunal by effectively taking on the prosecutor's role when the state failed to send a representative. The appellate panel noted that this issue arose in multiple involuntary commitment cases from Durham County during the same period, apparently due to a new county policy. The majority affirmed the commitment order, relying on reasoning set forth in a companion case, though one judge dissented.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a trial judge violates a respondent's right to an impartial tribunal by presenting the state's case when no state attorney appears at an involuntary commitment hearing
  • Procedural requirements for involuntary commitment hearings when the prosecuting authority is absent

Procedural posture

J.R. appealed from a trial court order of involuntary commitment entered after a hearing in which the state failed to send a representative.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

¶ 1 Respondent appeals from an involuntary commitment order committing him to an inpatient facility for a period not to exceed thirty (30) days.

I. Background

¶ 2 On 9 December 2019, Respondent J.R.’s interim guardian filed an affidavit and petition for involuntary commitment alleging that J.R. was mentally ill and dangerous to self or others. He was taken into custody the same day. J.R.’s involuntary commitment hearing was conducted on 3 January 2020 in Durham County by Judge Patricia Evans.

¶ 3 When J.R.’s case was called by the trial judge, no attorney appeared to represent the States interest in the matter. A doctor who had been subpoenaed by the State was present, along with J.R., his counsel, and the trial judge. J.R.’s counsel objected at the beginning of the hearing, arguing that the hearing could not proceed without a representative from the State. The judge proceeded, implicitly rejecting the objection. ¶ 4 The trial judge called the States sole witness, a doctor who had not evaluated J.R., and asked open-ended questions. J.R.’s attorney had the opportunity to cross-examine the doctor. J.R. was also called as a witness by his own attorney. At the conclusion of the hearing, the judge concluded that J.R. was mentally ill and dangerous to self, involuntarily committing him to thirty (30) days of inpatient treatment. J.R. appealed from the trial judges involuntary commitment order. 1

II. Analysis

¶ 5 J.R. argues that “the trial judge violated his right to an impartial tribunal by assuming the role of prosecutor by presenting the States case” when the State failed to appear at his involuntary commitment hearing.

¶ 6 This appeal and five others from Durham County involving involuntary commitments were heard by this panel on 10 March 2021. In each case, the State did not send a representative to the hearing, apparently as part of a new policy in Durham County.

2

In each matter, the respondents have raised the issue presented by J.R. in this appeal.

¶ 7 For the reasons stated in the majority opinion and concurring opinion addressing the “Due Process Concerns” issue in In re C.G., ––– N.C. App. ––––, 2021-NCCOA-344, one of the other involuntary commitment cases heard by this panel on 10 March 2021, we affirm the trial courts order.

AFFIRMED.

Report per Rule 30(e).

¶ 8 I dissent from the majority opinion for the reasons stated in my dissenting opinion in In re C.G., ––– N.C. App. ––––, 2021-NCCOA-344, a companion case heard by this panel on 10 March 2021.

FOOTNOTES

1

.   J.R.’s appeal is not moot even though his period of involuntary commitment has expired. See In re Hatley, 291 N.C. 693, 695, 231 S.E.2d 633, 635 (1977) (“The possibility that respondents commitment in this case might likewise form the basis for a future commitment, along with other obvious collateral consequences, convinces us that this appeal is not moot.”). 2

.   The trial judge responded to J.R.’s counsels objection to proceeding without a State representative by stating: “The District Attorneys Office of Durham County has notified this Court that they will not be participating in these hearings as in prior years, and this Court intends to go forward with this hearing, and the Respondent is more than welcome to appeal this Courts decision.” DILLON, Judge.

Judge HAMPSON concurs.

Judge GRIFFIN dissents.