HENNESY, Justice.

This case requires us to decide whether the legal test that Minnesota courts apply when ruling on petitions to administer involuntary intrusive treatments such as electroconvulsive therapy (ECT) to civilly committed individuals—the framework we

established in Price v. Sheppard, 239 N.W.2d 905 (Minn. 1976), and affirmed in Jarvis v. Levine, 418 N.W.2d 139 (Minn. 1988)—adequately addresses the statutory language setting forth a means for obtaining consent to any “treatment necessary to preserve the life

or health of any committed patient” in Minn. Stat. § 253B.03, subd. 6(b). Since 1988, district courts have decided such petitions using the Price/Jarvis balancing test, which requires courts to determine if the intrusive treatment is both “necessary and reasonable.”

Price, 239 N.W.2d at 910. Under this analysis, district courts “balance the patient’s need for treatment against the intrusiveness of the prescribed treatment” in light of six factors we outlined in Price. Id. at 913.

Generally, under Minn. Stat. § 253B.03, subd. 6(a), civilly committed individuals have the right to consent to medical and surgical treatments, including intrusive mental health treatments such as ECT. The statute—which was enacted after we decided Price— sets forth the procedures to obtain consent “for any treatment necessary to preserve the life or health of any committed patient[.]” Id., subd. 6(b). In such circumstances, if a committed individual is unable or refuses to consent and consent cannot be obtained from

an authorized representative or “nearest proper relative,” the statute authorizes the head of a treatment facility or state-operated treatment program, or an interested person, to petition the district court for authorization to administer intrusive treatments for mental illness. See id., subd. 6(b)(3).

In this case, appellant Leah Graeber, who is civilly committed, appealed a district court order authorizing involuntary ECT administration pursuant to this statute after applying the Price/Jarvis balancing test. In the court of appeals, she argued that the district court erred when it only applied the Price/Jarvis balancing test and did not separately

address the statutory language—“treatment necessary to preserve the life or health”—in Minn. Stat. § 253B.03, subd. 6(b). Graeber asserted this language imposes an additional requirement district courts must address before authorizing treatment. The court of appeals

rejected this argument and concluded the Price/Jarvis balancing test “subsume[s] the medical-necessity element that appellant wishes to have this court analyze separately,” observing that the court of appeals’ role is “limited to identifying errors and correcting

them.” In re Graeber, No. A24-0067, 2024 WL 2890845, at *4 (Minn. App. June 10, 2024). After further determining that the district court properly considered and balanced the Price/Jarvis factors, the court of appeals affirmed the ECT authorization. Id. at *4–7.

Graeber petitioned this court, arguing that the Price factors do not adequately consider the statutory language, and we granted review.

The question before us is thus whether the Price/Jarvis balancing test adequately addresses the language in Minn. Stat. § 253B.03, subd. 6(b), specifying that, when a treatment facility petitions a court to approve treatment, the treatment must be “necessary to preserve the life or health of any committed patient.” Minn. Stat. § 253B.03, subd. 6(b).

Because we conclude the balancing test we articulated in Price/Jarvis adequately addresses this statutory language, we affirm the court of appeals.

FACTS

Appellant Leah Graeber has been civilly committed on several occasions, beginning in 2001. Her current civil commitment was initiated in 2011 after she was found incompetent to proceed in a criminal vehicular homicide case. In that case, Graeber was accused of losing control of her vehicle while driving at a high speed and crashing into an oncoming vehicle, killing an 11-year-old boy and seriously injuring his family. During a competency evaluation, Graeber claimed the boy was not dead and declared herself God.

Graeber was diagnosed with schizoaffective disorder, bipolar type, with symptoms of psychosis and grandiose delusion, as well as multiple controlled-substance disorders. A district court committed her as a person who is mentally ill and dangerous pursuant to

Minn. Stat. § 253B.18, and her civil commitment became indeterminate in 2012. 1 Graeber has since resided at the state’s secure hospital in St. Peter.

In 2023, a psychiatrist at the hospital petitioned the district court for authorization to administer ECT to Graeber. ^[2] In the petition, the psychiatrist described Graeber’s

persistent symptoms of psychosis which led him to conclude that ECT was necessary, including “grandiosity[,] believing she is ‘God,’ paranoid and delusional thoughts about peers and staff, elevated mood with agitation, pressured speech, lack of insight, and verbal aggression at times.” The psychiatrist explained that ECT is “the least restrictive treatment for this patient at this time,” because “[a]fter exhausting the different psychotropic medication treatment modalities in addition to therapy,” Graeber’s “refractory symptoms

are preventing her from moving forward in treatment to a less restrictive setting.” The psychiatrist concluded that he could not obtain Graeber’s consent to ECT because Graeber

“lacks capacity to make a rational decision regarding the proposed treatment.” Because

Graeber could not consent, the psychiatrist petitioned the district court for authorization to

administer ECT pursuant to Minn. Stat. § 253B.03, subd. 6(b)(3) (authorizing the head of a treatment facility or state-operated treatment program, or an interested person, to petition the committing court to approve “any treatment necessary to preserve the life or health of any committed patient” when the patient, or patient’s relative or authorized representative, is unable to consent).

In making its decision on the petition to authorize ECT, the district court appointed two examiners to evaluate Graeber. The first examiner concluded that, under Price, ECT was reasonable and necessary to alleviate Graeber’s delusional thoughts and thought disorganization. The second examiner opined that ECT could “be expected to result in a stabilization of mood as well as a potential decrease in psychotic symptoms” and concluded that ECT was “medically necessary” under Price. ^[3] The second examiner concluded that

Graeber’s reasons for rejecting ECT were “based on delusion.” When the examiner attempted to determine whether Graeber would “prefer to stay in the hospital indefinitely” rather than receive ECT, Graeber responded that she would not need to stay in the facility much longer, with or without ECT, because “[p]eople will come to recognize that she is

God,” and that “the incompetent and stupid people who head the mental health system will be replaced.”

After considering the examiners’ findings and testimony at a hearing, 4 the district court issued an order authorizing ECT. The court found that Graeber’s “symptoms have persisted despite robust doses of neuroleptic medication” and that she “remains actively psychotic, persistently delusional, and in extreme denial.” The court concluded that

“[w]ithout ECT [Graeber]’s condition will likely remain the same and maybe even deteriorate. There are no viable treatment alternatives other than ECT . . . .” The district court applied the Price/Jarvis balancing test and made findings under each of its six factors. 5 The court found “clear and convincing evidence that the treatment of [Graeber]’s mental illness using ECT is necessary and reasonable.” The court authorized administering

Graeber a specified number and duration of ECT treatments.

Graeber appealed, arguing that the district court’s order was erroneous because it

did not separately analyze whether ECT treatment was “necessary to preserve [her] life or health” under Minn. Stat. § 253B.03, subd. 6. 6 Graeber, 2024 WL 2890845, at *4.

Graeber asserted that “necessary” within the statute means “absolutely needed or required,” and by that definition, ECT is not medically necessary for her. Id.

Reasoning that Graeber’s argument overlooked the framework for determining

whether a treatment is both necessary and reasonable established in Price, the court of appeals rejected her argument and affirmed the district court’s order authorizing ECT. Id. at *7. The court concluded that the Price/Jarvis balancing test “subsume[s] the medical- necessity element that appellant wishes to have this court analyze separately.” Id. at *4.

The court of appeals then reviewed the district court’s order and concluded that the district court’s findings under each of the six Price factors were supported by clear and convincing evidence. Id. at *5–7. As such, the court concluded that the record supported the district court’s ultimate finding that ECT was necessary and reasonable. Id. at *6–7. We granted

Graeber’s petition for review. 7

ANALYSIS

The sole issue before us is whether our Price/Jarvis balancing test—the test district courts currently apply when deciding petitions to administer intrusive forms of treatment such as ECT to civilly committed individuals without their consent—adequately addresses the statutory language in Minn. Stat. § 253B.03, subd. 6(b), specifying that a treatment

facility may bring such a petition for “treatment necessary to preserve the life or health of any committed patient.” 8 In order to make this determination, we first review our decisions in Price and Jarvis. Then, we interpret the statutory language at issue—“treatment necessary to preserve the life or health of any committed patient”—before deciding whether our Price/Jarvis balancing test adequately addresses the statutory phrase.

A.

We first recognized an individual’s constitutional right to privacy against intrusive medical treatment in our landmark decision in Price. Price, a minor, was civilly committed

in 1971 and admitted to a secure hospital due to mental illness and substance abuse. Price, 239 N.W.2d at 907. After his commitment, doctors diagnosed him with schizophrenia. Id. at 908. Price failed to respond to medication and remained aggressive and assaultive to staff and other patients. Id. The hospital’s medical director prescribed ECT, 9 and sought

Price’s mother’s consent for this treatment. Id. Price’s mother arranged for an examiner to conduct an independent medical examination. Id. The examiner recommended continuing treatment with medication, but, if Price’s condition did not improve, then administering ECT. Id. The hospital staff followed this recommendation. Id. When Price did not improve, the hospital administered ECT over the course of several weeks without

his mother’s consent. Id. Price’s mother later sued the hospital’s medical director for administering ECT to her son. Id. at 907.

When we decided Price, the statute in effect at the time—the Minnesota

Hospitalization and Commitment Act of 1967—did not include the language we interpret today: “necessary to preserve the life or health of any committed patient.” See Minn. Stat.

§§ 253A.01–.21 (1976). 10 In fact, although the statute contained provisions for obtaining consent “for a surgical operation necessary to save the life, health, eyesight, hearing, or a limb of any patient,” 11 it did not recognize a committed individual’s right to consent to any mental health treatment, nor did it require any court order to authorize such treatment.

Minn. Stat. § 253A.17, subd. ^[8] (1967). Consequently, the question before us in Price was whether the hospital involuntarily administering ECT to Price violated his constitutional right to privacy, not whether it violated the civil commitment statute. 12 239 N.W.2d at 908.

It was the Price decision that required treatment facilities to petition for court orders and district courts to decide these petitions using the criteria outlined, even though the statute at that time did not require consent or a court order to administer intrusive mental health treatments. Id. at 912–13; see Minn. Stat. § 253A.17, subd. ^[8] (1967).

In Price, we explained that at the core of the fundamental constitutional right to privacy is “the concept of personal autonomy—the notion that the Constitution reserves to the individual, free of governmental intrusion, certain fundamental decisions about how he or she will conduct his or her life.” 239 N.W.2d at 910. We acknowledged that, “[l]ike

other constitutional rights, . . . this right is not an absolute one and must give way to certain interests of the state, the balance turning on the impact of the decision on the life of the individual.” Id. We concluded that, in civil commitments, the state has a legitimate interest in treating a committed patient. Id. at 911.

In our Price opinion, we determined that the constitutional right to privacy requires that imposing intrusive forms of treatment not be “solely within the discretion of medical

personnel at our state hospitals.” Id. at 912–13. Accordingly, we adopted a procedure for treatment facilities to request court orders to authorize involuntary, intrusive mental health treatment with ECT. Id. at 913. In the absence of a patient’s or guardian’s consent, we

required a treatment facility to petition a district court for an order authorizing the treatment. Id. We held that, in an adversarial proceeding, the district court must determine whether the prescribed treatment is “necessary and reasonable” to justify infringing on an individual’s constitutional right to privacy. Id. And we outlined how district courts should make this determination:

the court should balance the patient’s need for treatment against the intrusiveness of the prescribed treatment. Factors which should be considered are (1) the extent and duration of changes in behavior patterns and mental activity effected by the treatment, (2) the risks of adverse side effects, (3) the experimental nature of the treatment, (4) its acceptance by the medical community of this state, (5) the extent of intrusion into the patient’s body and the pain connected with the treatment, and (6) the patient’s ability to competently determine for himself whether the treatment is desirable.

Id. (emphasis added). Although we did not list all intrusive forms of treatment subject to these procedures and the attendant analysis, we specifically observed that district courts are required to conduct this analysis for psychosurgery and ECT. ^[13] Id. Since our Price decision in 1976, district courts have applied this test in evaluating petitions seeking authorization to involuntarily administer ECT, balancing the need for treatment against its intrusiveness, and considering the factors we outlined.

We affirmed Price in Jarvis, holding that the Price test applies to all intrusive treatments for mental illness—including administering neuroleptic medication—and that treatment facilities must, therefore, obtain court orders to administer neuroleptic medication without consent. ^[14] Jarvis, 418 N.W.2d at 150. While the constitutional privacy interests we cited in Price were rooted in the federal constitution, in Jarvis, we held that the right to privacy separately emanated from the Minnesota Constitution. Id. at 147–48.

We decided Jarvis “exclusively under Minnesota statutes and our Minnesota Constitution”

because of the importance of “our obligation to be independently responsible for safeguarding the rights of our citizens.” 15 Id. (citation omitted) (internal quotation marks

omitted). In the years since Price and Jarvis, district courts have continued to apply the Price/Jarvis test, balancing the need for treatment against its intrusiveness and considering the six factors outlined in Price. 16 See, e.g., In re Commitment of Tefera, No. A10-1770, 2011 WL 781353, at *2 (Minn. App. Mar. ^[8], 2011) (stating that the district court must consider the Price balancing factors to determine the necessity and reasonableness of an intrusive treatment such as ECT); In re Commitment of DeRosia, No. A19-1350, 2020 WL

877054, at *4 (Minn. App. Feb. 24, 2020) (acknowledging that the district court applied the Price test when analyzing a request to administer neuroleptic medications to DeRosia).

B.

The statute we interpret today, found in the current Minnesota Commitment and Treatment Act, establishes civilly committed patients’ rights and the procedures that apply

to civil commitments. Minn. Stat. § 253B.03. Among those enumerated rights is the patient’s right to consent to treatment:

(a) A patient has the right to give prior consent to any medical or surgical treatment, other than treatment for chemical dependency or nonintrusive treatment for mental illness.

(b) The following procedures shall be used to obtain consent for any treatment necessary to preserve the life or health of any committed patient[.]

Id., subd. 6 (emphasis added). 17 The subsections that follow outline the methods for obtaining consent to the treatment requested, including getting written, informed consent

from a patient, patient’s guardian, authorized representative, or relative, and providing that, when such consent cannot be obtained, the head of a treatment facility or a state-operated treatment program, or an interested person, may petition the district court for an order authorizing the treatment. Id., subd. 6(b)(1)–(3). The statute does not specify

considerations a court must evaluate in deciding whether to authorize such treatment, nor does it require the court to make any particular findings before authorizing treatment.

Graeber argues that the current language of Minn. Stat. § 253B.03, subd. 6(b)— which states, “[t]he following procedures shall be used to obtain consent for any treatment necessary to preserve the life or health of any committed patient”— requires a district court to make a threshold determination that the proposed treatment is necessary to preserve a patient’s life or health before applying the Price/Jarvis balancing test. Respondent Dakota

County Social Services (the County) opposes Graeber’s proposed two-step analysis, arguing that Graeber’s reading of “necessary to preserve the life or health” in Minn. Stat.

§ 253B.03, subd. 6(b), is unreasonably narrow and would only allow physicians to petition for treatment when necessary to save a patient’s life.

To decide whether the Price/Jarvis balancing test necessarily and adequately addresses the statutory phrase “treatment necessary to preserve the life or health,” we must first determine what this phrase means. This is a question of statutory interpretation, which we review de novo. In re Benson, 12 N.W.3d 711, 715 (Minn. 2024).

“The object of all interpretation and construction of laws is to ascertain and effectuate the intention of the legislature.” Minn. Stat. § 645.16. “[W]hen interpreting a statute, the first step is to determine whether the plain language of the statute is ambiguous.” State v. Moore, 10 N.W.3d 676, 680 (Minn. 2024). When the plain language

of a statute is unambiguous, then the plain meaning controls. Id. If, however, the plain language of the statute is subject to “more than one reasonable interpretation,” the statute is ambiguous. Benson, 12 N.W.3d at 715 (citation omitted) (internal quotations omitted).

Only if we conclude the language is ambiguous will we go beyond the plain language of the statute to determine the Legislature’s intent. Id. at 715. In assessing a statute’s words and phrases, we construe the language “according to [its] common and approved usage.”

Minn. Stat. § 645.08(1).

Accordingly, we begin our interpretation of the statutory language “treatment

necessary to preserve the life or health of any committed patient” in Minn. Stat. § 253B.03, subd. 6(b), by examining the plain language. We have not previously interpreted this phrase, and the statute does not define the words at the heart of the parties’ dispute:

“preserve” and “health.” 18 “When the Legislature has not provided definitions of the relevant terms, we may consider dictionary definitions to determine a word’s common usage.” State v. Cummings, 2 N.W.3d 528, 533 (Minn. 2024).

Both parties assert the statute’s plain meaning is unambiguous. Graeber argues that

“preserve” means to “keep safe from injury, harm, or destruction: protect.” Merriam-

Webster’s Collegiate Dictionary 982 (11th ed. 2003) (defining “preserve” as “to keep safe

from injury, harm, or destruction: protect”). Here, because she believes that no injury, harm, or destruction will occur if she does not receive ECT, Graeber asserts that her health does not need protection. As such, Graeber’s narrow interpretation would allow treatment only to maintain a patient’s current condition and prevent their health from deteriorating.

The County, on the other hand, focuses on the word “health” in arguing for a broader interpretation to include treatments that provide relief from symptoms negatively

impacting a person’s mental health. ^[19] The County argues that “health,” as it is used in the statute, means “the condition of being sound in body, mind, or spirit.” Id. at 574 (defining

“health” as “the condition of being sound in body, mind, or spirit; esp: freedom from physical disease or pain”). Under the County’s broader interpretation, preserving health could include treatments that would improve a patient’s current condition so that the patient would be “sound in body, mind, or spirit.” 20

When we consider competing dictionary definitions, “we evaluate and reject various definitions until we ascertain the only reasonable definition.” Cummings, 2 N.W.3d at 534.

We have also observed that the “relevant definition of a term depends on the context in which the term is used.” State v. Nelson, 842 N.W.2d 433, 437 n.2 (Minn. 2014).

We conclude that Graeber’s narrow interpretation of the language “treatment

necessary to preserve the life or health of any committed patient” in Minn. Stat. § 253B.03, subd. 6(b), is not reasonable in the context of this statute. Graeber’s suggested dictionary definition of “preserve” is not in itself problematic. But Graeber argues that because

“preserve” means to “keep safe from injury, harm, or destruction: protect,” intrusive mental health treatments cannot be administered without a patient’s consent unless the patient will suffer injury, harm, or destruction without such treatments. See Merriam-Webster’s

Collegiate Dictionary 982 (11th ed. 2003). The problem with this proposed interpretation

is Graeber’s reliance on the isolated meaning of “preserve” without considering the interaction between “preserve” and “health” in the context of the statutory phrase

“necessary to preserve the life or health.” See Minn. Stat. § 253B.03, subd. 6(b). If a person’s health means the “condition of being sound in body, mind, or spirit,” preserving or protecting a person’s health means protecting a person’s sound condition or healthiness.

See Merriam-Webster’s Collegiate Dictionary 574 (11th ed. 2003). While Graeber’s interpretation might make sense for a currently healthy person, for a person who is injured or ill this interpretation would mean that the statute was intended to maintain their injury or disease in its current condition rather than restoring health. Under Graeber’s interpretation, a court could never authorize an intrusive mental health treatment to improve a civilly committed person’s mental health, no matter how badly the person’s mental health had deteriorated. This cannot be a reasonable interpretation of this statute.

Accordingly, we conclude that Graeber’s narrow interpretation of “necessary to

preserve the life or health of a committed patient,” which results in merely maintaining the status quo for civilly committed patients with serious and persistent mental illness, is not reasonable. We reject this narrow definition in favor of a broader interpretation that

appropriately considers the meaning and relationship between the terms “preserve” and “health,” and which includes treatments that alleviate mental illness’s harmful symptoms in order to restore a person’s health.

C.

Finally, we turn to the question of the ongoing validity of the Price/Jarvis balancing test. This question is not one of statutory interpretation but rather interpreting our own jurisprudence. Graeber asserts that the statutory language “treatment necessary to preserve the life or health of any committed patient” in Minn. Stat. § 253B.03, subd. 6(b), is a separate requirement in addition to the Price/Jarvis factors because those six factors do not address that specific statutory requirement. Graeber advocates for a new rule of law that would require district courts to first analyze whether treatment is “necessary to preserve the life or health” of a committed individual and then apply the Price/Jarvis balancing test before deciding whether to authorize intrusive mental health treatment. As such, we must decide whether our Price/Jarvis balancing test adequately addresses the “necessary to preserve the life or health” language of Minn. Stat. § 253B.03, subd. 6(b). After comparing the two, we conclude that it does.

First, we examine the statutory language. Having concluded that Graeber’s narrow interpretation of the phrase “necessary to preserve the life or health” is unreasonable, we interpret the statutory phrase at issue as including treatments that alleviate harmful mental illness symptoms in order to restore a person’s health. Yet even with this broader interpretation, the statutory language remains focused on the necessity of such treatment.

The Price/Jarvis balancing test, however, addresses two fundamental concerns: necessity and intrusiveness. Price, 239 N.W.2d at 910. In Price, we described the first concern, necessity, as the “need for treatment.” Id. at 913. As such, under the Price/Jarvis balancing test, a district court must assess the necessity of the proposed treatment, which requires the court to consider the patient’s current condition and symptoms. See id. at 911–

12. And district courts must weigh the necessity of the treatment against the second consideration, the treatment’s intrusiveness, which focuses on whether the intrusion is reasonable, or “in light of alternative means, the least intrusive”—the salient consideration in a constitutional privacy analysis. Id. at 910.

Consequently, we conclude that the concern underlying the statute’s language—that treatment be “necessary to preserve the life or health” of the committed patient—is fundamentally the same concern for necessity that the Price/Jarvis test addresses: the need

for the treatment. As such, our Price/Jarvis balancing test adequately addresses the “treatment necessary to preserve the life or health” language of Minn. Stat. § 253B.03, subd. 6(b), and also provides additional, important protection for patients’ constitutional privacy rights. See Price, 239 N.W.2d at 910–11; Jarvis, 418 N.W.2d at 148–50.

Therefore, when a district court makes the required findings under the Price/Jarvis balancing test that a treatment is both necessary and reasonable (i.e., the least intrusive means available), such a finding satisfies not only the important individual constitutional privacy interests but also adequately addresses the statutory language.

Graeber’s argument and the dissent’s reasoning disregard the overarching concern of our Price/Jarvis balancing test. Graeber and the dissent focus on the six factors listed in Price, arguing that the factors do not address whether a treatment is “necessary to preserve life or health.” But the Price/Jarvis balancing test involves more than analyzing

the six outlined factors. Those factors guide a district court’s analysis of one half of the balancing test: reasonableness—the extent of the proposed treatment’s intrusion on an individual’s privacy interest. The second half of the balancing test requires the district court to weigh “the patient’s need for treatment against the intrusiveness of the prescribed treatment.” Price, 239 N.W.2d at 913. Ultimately, district courts are tasked with weighing both important principles: necessity and reasonableness. Because the test requires district courts to make a finding that the treatment is both “necessary and reasonable” in order to authorize treatment, it necessarily encompasses a patient’s need for treatment. Id. We therefore conclude that this careful and detailed inquiry 21 satisfies the “treatment necessary to preserve the life or health” language of Minn. Stat. § 253B.03, subd. 6(b).

In sum, the Legislature did not create a separate test, in addition to the Price/Jarvis balancing test, by requiring that district courts consider whether a treatment is “necessary to preserve the life or health of any committed patient” in deciding whether to authorize that treatment under the Minnesota Commitment and Treatment Act. 22 In the past thirty- plus years that this statutory language and the Price/Jarvis balancing test have been in effect, although the Legislature has amended the Minnesota Commitment and Treatment

Act, it has not amended it to require district courts to make findings beyond those required under the Price/Jarvis balancing test. This supports our conclusion that the Price/Jarvis balancing test addresses both constitutional privacy interests and the statutory language governing authorizing treatment procedures and remains valid.

* * *

We affirm the validity of our longstanding Price/Jarvis balancing test, which provides essential protections to civilly committed individuals in Minnesota. The test ensures that treatment facilities may not impose involuntary intrusive treatments such as

ECT without a court first determining that the treatment is “necessary and reasonable,” after balancing the patient’s need for the treatment and the intrusiveness of the treatment.

See Price, 239 N.W.2d at 910. We hold that the Price/Jarvis balancing test not only

protects an individual’s constitutional right to privacy, but it adequately addresses the Minn. Stat. § 253B.092 after we pointed out that mentally ill persons may be competent to make some medical decisions in Jarvis. Compare Jarvis, 418 N.W.2d at 148 n.7 (noting that “mentally ill persons may be competent to make some medical decisions” and expressing our view that “a finding of legal incompetence is a prerequisite to involuntary medication with neuroleptics”), with Act of May 22, 1997, ch. 217, § 60, 1997 Minn. Laws 2138, 2161 (codified at Minn. Stat. § 253B.092, subd. 6(d) (1997)) (stating, in the context of authorizing administration of neuroleptic medications, that “the court shall make findings regarding the patient’s capacity to make decisions” (emphasis added)). The Legislature did not, however, include language in the statute explicitly requiring district courts to make any particular findings before performing the Price/Jarvis balancing test. If the Legislature had wished to impose a threshold finding or change the Price/Jarvis balancing test, the Legislature was capable of doing so outright, as it did with the 1997 amendments requiring findings regarding a patient’s capacity to make decisions after our 1988 Jarvis decision.

“necessary to preserve the life or health of any committed patient” language of Minn. Stat.

§ 253B.03, subd. 6(b).

CONCLUSION

For the foregoing reasons, we affirm the decision of the court of appeals.

Affirmed.

DISSENT

PROCACCINI, Justice (dissenting).

I respectfully dissent. I would conclude that the phrase “necessary to preserve the life or health of any committed patient” in Minnesota Statutes section 253B.03, subdivision 6(b), imposes a threshold requirement for hospitals to petition courts for authorization to administer intrusive treatment to committed patients. This statutory

threshold requirement and the constitutional balancing test outlined in Price v. Sheppard, 239 N.W.2d 905 (Minn. 1976), are different requirements that must be independently addressed before a court may order a patient to undergo involuntary electroconvulsive therapy (ECT).

Because the statutory threshold requirement and the constitutional balancing test impose distinct procedural requirements and answer different substantive questions, I

would hold that a district court errs when—as happened here—it does not consider the statutory threshold requirement independently and determine whether the treatment sought is “necessary to preserve the life or health” of the patient.

A.

Attempts to reconcile the subdivision 6(b) statutory threshold requirement and the constitutional balancing test by subsuming one within the other fail because they are simply different—both procedurally and substantively. Procedurally, the statutory threshold requirement plays a gatekeeping function, establishing when a hospital can seek consent to administer intrusive treatment to a committed patient via a court petition under subdivision 6(b)(3). And courts apply the constitutional balancing test when deciding

D-1

whether to authorize intrusive treatment sought in such a petition, addressing the appropriateness of the intrusion posed by a particular treatment. Substantively, the statutory threshold requirement and the constitutional balancing test ask different questions that cannot be applied interchangeably. As addressed below, these differences make sense

in light of the different purposes served by the statutory threshold requirement and constitutional balancing test, as well as the history of their development.

To start, the statutory threshold requirement is not subsumed within the constitutional balancing test because it is an independent procedural requirement that plays a distinct role. Together, the statutory threshold requirement and the constitutional balancing test call for a two-step procedure for the district court to follow when a hospital seeks to administer intrusive treatment to a non-consenting committed patient.

The first step is the express statutory threshold requirement that the treatment to be administered is “necessary to preserve the life or health of [the] committed patient.” Minn.

Stat. § 253B.03, subd. 6(b). Subdivision 6(b) functions as a gatekeeper. It explains when a hospital may seek consent via a court petition to administer intrusive treatment to a

committed patient under subdivision 6(b)(3). Subdivision 6 begins by establishing the baseline principle that “[a] patient has the right to give prior consent to any medical or surgical treatment, other than treatment for chemical dependency or nonintrusive treatment for mental illness.” 1 Id., subd. 6(a). Having codified the right of all patients to consent to treatment, the statute explains that “[t]he following procedures shall be used to obtain