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15 Washington opinions name it 2 courts 1986–2026 3 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In Re the Detention of LaBellegreen2 sentences2026Under the gravely disabled standard, “the potential for harm must be ‘great enough to justify such a massive curtailment of liberty.’ ” LaBelle, 107 Wn.2d at 204 (internal quotation marks omitted) (quoting In re Harris, 98 Wn.2d 276, 283 , 654 P.2d 109 (1982)). 2020In Labelle, the Supreme Court held that when the State proceeds under the gravely disabled standard, it "must present recent, tangible evidence of failure or inability to provide for such essential human needs as food, clothing, shelter, and medical treatment which presents a high probability of serious physical harm within the near future unless adequate treatment is afforded." Labelle, 107 Wn.2d at 204-05 . | 2 | 10 |
In re the Detention of M.K.green2 sentences2026See In re Det. of M.K., 168 Wn. 2023It is well established that an appeal of an involuntary commitment order based on the gravely disabled standard is generally not moot because “a trial court presiding over future involuntary commitment hearings may consider . . . prior involuntarily commitment orders when making its commitment determination.” In re Det. of M.K., 168 Wn. | 1 | 4 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Detention of CW
green
2 sentences2003In re Det. of C.W., 147 Wn.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Det. of Swanson, 115 Wn.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re Det. of LaBelle, 107 Wn.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard of civil commitment statutes). 2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard | 2 | 2003–2003 |
In re the Detention of C.W.
green
2 sentences2003In re Det. of C.W., 147 Wn.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Det. of Swanson, 115 Wn.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re Det. of LaBelle, 107 Wn.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard of civil commitment statutes). 2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard | 2 | 2003–2003 |
In Re the Detention Swanson
green
2 sentences2003In re Det. of C.W., 147 Wn.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Det. of Swanson, 115 Wn.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re Det. of LaBelle, 107 Wn.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard of civil commitment statutes). 2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard | 2 | 2003–2003 |
Matter of Harris
green
2 sentences2026Under the gravely disabled standard, “the potential for harm must be ‘great enough to justify such a massive curtailment of liberty.’ ” LaBelle, 107 Wn.2d at 204 (internal quotation marks omitted) (quoting In re Harris, 98 Wn.2d 276, 283 , 654 P.2d 109 (1982)). 2026Under the gravely disabled standard, “the potential for harm must be ‘great enough to justify such a massive curtailment of liberty.’ ” LaBelle, 107 Wn.2d at 204 (internal quotation marks omitted) (quoting In re Harris, 98 Wn.2d 276, 283 , 654 P.2d 109 (1982)). | 1 | 2026–2026 |
Westerman v. Cary
green
2 sentences2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard 2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard | 1 | 2003–2003 |
Sorenson v. City of Bellingham
green
2 sentences2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard 2003Westerman, 125 Wash.2d at 286 , 892 P.2d 1067 (citing Sorenson v. Bellingham, 80 Wash.2d 547, 558 , 496 P.2d 512 (1972)). [5] In re C.W., 147 Wash.2d 259, 270 , 53 P.3d 979 (2002) (clarifying application of statutory six-hour time limit in which to refer a person for mental health services); In re Swanson, 115 Wash.2d 21, 24-25 , 804 P.2d 1 (1990) (clarifying when, for purposes of the civil commitment statute, the 72-hour detention period stipulated by statute begins and ends); In re LaBelle, 107 Wash.2d 196, 200 , 728 P.2d 138 (1986) (clarifying issues concerning the gravely disabled standard | 1 | 2003–2003 |
Humphrey v. Cady
green
2 sentences1986Under either standard, the potential for harm must be " 'great enough to justify such a massive curtailment of liberty.'" Harris , at 283, quoting Humphrey v. Cady, 405 U.S. 504, 509 , 31 L. 1986Under either standard, the potential for harm must be " 'great enough to justify such a massive curtailment of liberty.'" Harris , at 283, quoting Humphrey v. Cady, 405 U.S. 504, 509 , 31 L. | 1 | 1986–1986 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.