L.S., A CHILD v. STATE OF FLORIDA  ·  2022-06-08  ·  District Court of Appeal of Florida  ·  pin 765 So. 2d at 276

“Denial of the due process right to be heard prior to deprivation of one’s liberty is fundamental error which may be raised on appeal even if not preserved below.”

In re the Care & Treatment of Ontiberos  ·  2012-08-17  ·  Supreme Court of Kansas  ·  pin 765 So. 2d at 276

“Because involuntary commitment is a substantial deprivation of liberty at which fundamental due process protections must attach, dre patient cannot be denied the right to be present, to be represented by counsel, and to be heard.”

Burley v. State  ·  2011-01-19  ·  District Court of Appeal of Florida  ·  2 pin-cites  ·  pin 765 So. 2d at 276

"Because involuntary commitment is a substantial deprivation of liberty at which fundamental due process protections must attach, the patient cannot be denied the right to be present, to be represented by counsel, and to be heard."