involuntary commitment hearing (Iowa) · Go Syfert
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involuntary commitment hearing in Iowa

9 Iowa opinions name it 2 courts 2001–2023 1 in the last five years

The cases below were cited by Iowa 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 (7)

CaseFollowedCited
In Re MTgreen
iowa · 2001 · cited in 4 Iowa opinions naming this issue, 2007–2023
2 sentences

2023See In re M.T., 625 N.W.2d 702, 706 (Iowa 2001) (en banc) (“[A] respondent’s liberty interests are at stake at an involuntary commitment hearing.”). “[O]nce it is determined due process applies, the question remains what process is due.” In re G.G., 165 A.3d at 1085 (alteration in original) (quoting Morrissey v. Brewer, 408 U.S. 471, 481 (1972)).

2017Because “a respondent’s liberty interests are at stake [in] an involuntary commitment hearing,” due process re *481 quires “that the statutory requirements and procedures be followed.” In re M.T., 625 N.W.2d 702, 706 (Iowa 2001).

44
In Re RPgreen
iowa · 2000 · cited in 4 Iowa opinions naming this issue, 2001–2006
2 sentences

2006She argues her due process rights were violated because the nature and extent of the court's questions rose to the level of advocacy. [3] The issue of a referee taking on an adversarial role during an involuntary commitment hearing was brought before this court in In re R.P., 606 N.W.2d 15 (Iowa 2000).

2006She argues her due process rights were violated because the nature and extent of the court’s questions rose to the level of advocacy. 3 The issue of a referee taking on an adversarial role during an involuntary commitment hearing was brought before this court in In re R.P., 606 N.W.2d 15 (Iowa 2000).

24
Addington v. Texasgreen
scotus · 1979 · cited in 2 Iowa opinions naming this issue, 2001–2001
2 sentences

2001See Addington v. Texas, 441 U.S. 418, 425 , 99 S.Ct. 1804, 1809 , 60 L.Ed.2d 323, 330-31 (1979) (holding that "civil commitment for any purpose constitutes a significant deprivation of liberty that requires due process protection"); In re R.P., 606 N.W.2d 15, 17 (Iowa 2000) (same).

2001See Addington v. Texas, 441 U.S. 418, 425 , 99 S.Ct. 1804, 1809 , 60 L.Ed.2d 323, 330-31 (1979) (holding that "civil commitment for any purpose constitutes a significant deprivation of liberty that requires due process protection"); In re R.P., 606 N.W.2d 15, 17 (Iowa 2000) (same).

22
Morrissey v. Brewergreen
scotus · 1972 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023See In re M.T., 625 N.W.2d 702, 706 (Iowa 2001) (en banc) (“[A] respondent’s liberty interests are at stake at an involuntary commitment hearing.”). “[O]nce it is determined due process applies, the question remains what process is due.” In re G.G., 165 A.3d at 1085 (alteration in original) (quoting Morrissey v. Brewer, 408 U.S. 471, 481 (1972)).

11
In re G.G.green
vt · 2017 · cited in 1 Iowa opinions naming this issue, 2023–2023
2 sentences

2023The In re G.G. court also emphasized the circularity problem inherent in allowing self-representation in an involuntary commitment hearing: [A] mental health patient who represents him or herself and who is adjudicated in need of commitment or medication would then be in a position to challenge the initial waiver of counsel as not knowing, intelligent or voluntary and thereby claiming a right to a new hearing with counsel. 165 A.3d at 1090 .

2023See In re M.T., 625 N.W.2d 702, 706 (Iowa 2001) (en banc) (“[A] respondent’s liberty interests are at stake at an involuntary commitment hearing.”). “[O]nce it is determined due process applies, the question remains what process is due.” In re G.G., 165 A.3d at 1085 (alteration in original) (quoting Morrissey v. Brewer, 408 U.S. 471, 481 (1972)).

11
Mathews v. Eldridgegreen
scotus · 1976 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023The In re G.G. court applied the Mathews three-factor test, see Mathews v. Eldridge, 424 U.S. 319, 335 (1976), examining: “(i) the interests of the individual; (ii) the governmental interest affected; and (iii) the risk of erroneous deprivation of the individual’s interests if the right he or she asserts is not recognized, and the probable value, if any, of recognizing that right.” 165 A.3d at 1085–86.

11
In re T.S.green
iowa · 2005 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017See 705 N.W.2d at 502 .

11

Distinguished, questioned or overruled (0)

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

Statutes the citing opinions construe

IA § Iowa Code § 229.12 (3) IA § Iowa Code § 229.6 (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

NC 14 (2011–2022) IL 13 (1993–2025) IA 9 (2001–2023) AZ 7 (2007–2026) FL 6 (1998–2022) WA 6 (1999–2025) ME 5 (2005–2026) TX 4 (2000–2006) ND 3 (2002–2020) AK 3 (2020–2023) WY 3 (2014–2014) IN 2 (2015–2018) WI 2 (1987–2001) MT 2 (2009–2025) PA 2 (1980–2023) AL 2 (1988–2012)

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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