civil commitment hearing in Washington

2009Cf. Dutcher, 114 Wash.App. at 765-66 , 60 P.3d 635 ("The legislature has ... not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing."). ¶ 30 The majority's contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that "[t]he Legislature `does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.'" In re Recall of Pearsall-Stipek, 141 Wash.2d 756, 769 , 1

2009App. at 765-66 (“The legislature has . . . not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing.”). ¶30 The majority’s contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that “[t]he Legislature ‘does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.’ ” In re Recall of Pearsall-Stipek, 141 Wn.2d 756, 769 , 10 P.3d 1034 (2000) (quoting John H.

2009Cf. Dutcher, 114 Wash.App. at 765-66 , 60 P.3d 635 ("The legislature has ... not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing."). ¶ 30 The majority's contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that "[t]he Legislature `does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.'" In re Recall of Pearsall-Stipek, 141 Wash.2d 756, 769 , 1

2009App. at 765-66 (“The legislature has . . . not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing.”). ¶30 The majority’s contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that “[t]he Legislature ‘does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.’ ” In re Recall of Pearsall-Stipek, 141 Wn.2d 756, 769 , 10 P.3d 1034 (2000) (quoting John H.

2007See, for example, our Supreme Court’s description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wn.2d 561, 587-88 , 23 P.3d 1046 (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cer t. denied, 534 U.S. 964 (2001).

2007See, for example, our Supreme Court's description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wash.2d 561, 587-88 , 23 P.3d 1046 (2001) (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cert. denied, 534 U.S. 964 , 122 S.Ct. 374 , 151 L.Ed.2d 285 (2001).

2007See, for example, our Supreme Court’s description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wn.2d 561, 587-88 , 23 P.3d 1046 (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cer t. denied, 534 U.S. 964 (2001).

2007See, for example, our Supreme Court's description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wash.2d 561, 587-88 , 23 P.3d 1046 (2001) (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cert. denied, 534 U.S. 964 , 122 S.Ct. 374 , 151 L.Ed.2d 285 (2001).

2007See, for example, our Supreme Court’s description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wn.2d 561, 587-88 , 23 P.3d 1046 (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cer t. denied, 534 U.S. 964 (2001).

2007See, for example, our Supreme Court's description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wash.2d 561, 587-88 , 23 P.3d 1046 (2001) (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cert. denied, 534 U.S. 964 , 122 S.Ct. 374 , 151 L.Ed.2d 285 (2001).

2007A patient’s claimed right to self-representation at a civil commitment hearing is an issue of first impression in Washington. 2 See McLaughlin, 100 Wn.2d at 838 ; Cross, 99 Wn.2d at 377-78 .

2007A patient's claimed right to self-representation at a civil commitment hearing is an issue of first impression in Washington. [2] See McLaughlin, 100 Wash.2d at 838 , 676 P.2d 444 ; Cross, 99 Wash.2d at 377-78 , 662 P.2d 828 .

2007A patient’s claimed right to self-representation at a civil commitment hearing is an issue of first impression in Washington. 2 See McLaughlin, 100 Wn.2d at 838 ; Cross, 99 Wn.2d at 377-78 .

2007A patient's claimed right to self-representation at a civil commitment hearing is an issue of first impression in Washington. [2] See McLaughlin, 100 Wash.2d at 838 , 676 P.2d 444 ; Cross, 99 Wash.2d at 377-78 , 662 P.2d 828 .

2021When determining due process rights, we utilize the balancing test from Mathews v. Eldridge, 424 U.S. 319 , 96 S. Ct. 893 , 47 L.

2021When determining due process rights, we utilize the balancing test from Mathews v. Eldridge, 424 U.S. 319 , 96 S. Ct. 893 , 47 L.

2009Cf. Dutcher, 114 Wash.App. at 765-66 , 60 P.3d 635 ("The legislature has ... not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing."). ¶ 30 The majority's contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that "[t]he Legislature `does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.'" In re Recall of Pearsall-Stipek, 141 Wash.2d 756, 769 , 1

2009Cf. Dutcher, 114 Wash.App. at 765-66 , 60 P.3d 635 ("The legislature has ... not authorized any exemption from this process simply because [the End of Sentence Review Committee] believes the offender qualifies for a civil commitment hearing."). ¶ 30 The majority's contrary understanding of the applicable statute contravenes the well-settled principle of statutory construction that "[t]he Legislature `does not engage in unnecessary or meaningless acts, and we presume some significant purpose or objective in every legislative enactment.'" In re Recall of Pearsall-Stipek, 141 Wash.2d 756, 769 , 1

2007Dec. 540 (1999); 5 In re Condition of S.Y., 156 Wis. 2d 317 , 457 N.W.2d 326 (Ct. App. 1990); see also North Dakota’s statutory provision. 6 ¶33 The Illinois Court of Appeals premises its Dennis analysis on Illinois’s statutory scheme for civil commitment, which presumes a defendant to be legally competent at the outset of the civil commitment hearing and requires a separate determination of incompetency to overcome this presumption. 7 Dennis, 707 N.E.2d at 670 .

2007Dec. 540 (1999); 5 In re Condition of S.Y., 156 Wis. 2d 317 , 457 N.W.2d 326 (Ct. App. 1990); see also North Dakota’s statutory provision. 6 ¶33 The Illinois Court of Appeals premises its Dennis analysis on Illinois’s statutory scheme for civil commitment, which presumes a defendant to be legally competent at the outset of the civil commitment hearing and requires a separate determination of incompetency to overcome this presumption. 7 Dennis, 707 N.E.2d at 670 .

2007See, for example, our Supreme Court's description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wash.2d 561, 587-88 , 23 P.3d 1046 (2001) (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cert. denied, 534 U.S. 964 , 122 S.Ct. 374 , 151 L.Ed.2d 285 (2001).

2007See, for example, our Supreme Court's description of a meaningful colloquy in the criminal context in Washington: State v. Woods, 143 Wash.2d 561, 587-88 , 23 P.3d 1046 (2001) (once a defendant unequivocally waives his right to counsel, the trial court should inform the defendant of the charges against him, warn him of the possible penalties and consequences, and advise him of the disadvantages of self-representation), cert. denied, 534 U.S. 964 , 122 S.Ct. 374 , 151 L.Ed.2d 285 (2001).