gravely disabled standard (Washington) · Go Syfert
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gravely disabled standard in Washington

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.

Followed or applied (2)

CaseFollowedCited
In Re the Detention of LaBellegreen
wash · 1986 · cited in 10 Washington opinions naming this issue, 2001–2026
2 sentences

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)).

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 .

210
In re the Detention of M.K.green
washctapp · 2012 · cited in 4 Washington opinions naming this issue, 2019–2026
2 sentences

2026See 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.

14

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
In Re Detention of CW green
wash · 2002
2 sentences

2003In 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

22003–2003
In re the Detention of C.W. green
wash · 2002
2 sentences

2003In 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

22003–2003
In Re the Detention Swanson green
wash · 1990
2 sentences

2003In 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

22003–2003
Matter of Harris green
wash · 1982
2 sentences

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)).

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)).

12026–2026
Westerman v. Cary green
wash · 1995
2 sentences

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

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

12003–2003
Sorenson v. City of Bellingham green
wash · 1972
2 sentences

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

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

12003–2003
Humphrey v. Cady green
scotus · 1972
2 sentences

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.

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.

11986–1986

Statutes the citing opinions construe

WA § Wash. Rev. Code § 71.05.020 (11) WA § Wash. Rev. Code § 71.05.240 (10) WA § Wash. Rev. Code § 2.06.040 (5) WA § Wash. Rev. Code § 71.05.010 (5) WA § Wash. Rev. Code § 71.05.310 (5) WA § Wash. Rev. Code § 71.05.320 (5) WA § Wash. Rev. Code § 71.05.280 (4) WA § Wash. Rev. Code § 71.05.012 (3) WA § Wash. Rev. Code § 71.05.230 (3) WA § Wash. Rev. Code § 71.05.245 (3) WA § Wash. Rev. Code § 71.05.285 (3)

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.

Where else courts name it

WA 15 (1986–2026) CA 2 (1977–2021)

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.

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