Wash. Rev. Code § 71.05.150
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(1) When a designated crisis responder receives information alleging that a person, as a result of a behavioral health disorder, presents a likelihood of serious harm or is gravely disabled, the designated crisis responder may, after investigation and evaluation of the specific facts alleged and of the reliability and credibility of any person providing information to initiate detention, if satisfied that the allegations are true and that the person will not voluntarily seek appropriate treatment, file a petition for initial detention under this section. Before filing the petition, the designated crisis responder must personally interview the person, unless the person refuses an interview, and determine whether the person will voluntarily receive appropriate evaluation and treatment at an evaluation and treatment facility, crisis stabilization unit, 23-hour crisis relief center, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. As part of the assessment, the designated crisis responder must attempt to ascertain if the person has executed a mental health advance directive under chapter 71.32 RCW. The interview performed by the designated crisis responder may be conducted by video provided that a licensed health care professional or professional person who can adequately and accurately assist with obtaining any necessary information is present with the person at the time of the interview.
(2)(a) A superior court judge may issue a warrant to detain a person with a behavioral health disorder to a designated evaluation and treatment facility, a secure withdrawal management and stabilization facility, or an approved substance use disorder treatment program, for a period of not more than 120 hours for evaluation and treatment upon request of a designated crisis responder, subject to (d) of this subsection, whenever it appears to the satisfaction of the judge that:
(i) There is probable cause to support the petition; and
(ii) The person has refused or failed to accept appropriate evaluation and treatment voluntarily.
(b) The petition for initial detention, signed under penalty of perjury, or sworn telephonic testimony may be considered by the court in determining whether there are sufficient grounds for issuing the order.
(c) The order shall designate retained counsel or, if counsel is appointed from a list provided by the court, the name, business address, and telephone number of the attorney appointed to represent the person.
(d) A court may not issue an order to detain a person to a secure withdrawal management and stabilization facility or approved substance use disorder treatment program unless there is an available secure withdrawal management and stabilization facility or approved substance use disorder treatment program that has adequate space for the person.
(e) If the court does not issue an order to detain a person pursuant to this subsection (2), the court shall issue an order to dismiss the initial petition.
(3) The designated crisis responder shall then serve or cause to be served on such person and his or her guardian, if any, a copy of the order together with a notice of rights, and a petition for initial detention. After service on such person the designated crisis responder shall file the return of service in court and provide copies of all papers in the court file to the evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program, and the designated attorney. The designated crisis responder shall notify the court and the prosecuting attorney that a probable cause hearing will be held within 120 hours of the date and time of outpatient evaluation or admission to the evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. The person shall be permitted to be accompanied by one or more of his or her relatives, friends, an attorney, a personal physician, or other professional or religious advisor or traditional cultural healer to the place of evaluation. An attorney accompanying the person to the place of evaluation shall be permitted to be present during the admission evaluation. Any other individual accompanying the person may be present during the admission evaluation. The facility may exclude the individual if his or her presence would present a safety risk, delay the proceedings, or otherwise interfere with the evaluation.
(4) The designated crisis responder may notify a peace officer to take such person or cause such person to be taken into custody and placed in an evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. At the time such person is taken into custody there shall commence to be served on such person, his or her guardian, and conservator, if any, a copy of the original order together with a notice of rights and a petition for initial detention.
(5) In any investigation and evaluation of an individual under this section or RCW 71.05.153 in which the designated crisis responder knows, or has reason to know, that the individual is an American Indian or Alaska Native who receives medical or behavioral health services from a tribe within this state, the designated crisis responder shall notify the tribe and Indian health care provider whether or not a petition for initial detention or involuntary outpatient treatment will be filed as soon as possible, but no later than three hours from the time the decision is made. If a petition for initial detention or involuntary outpatient treatment is filed, the designated crisis responder must provide the tribe and Indian health care provider with a copy of the petition, together with any orders issued by the court and a notice of the tribe's right to intervene as soon as possible, but before the hearing, and no later than 24 hours from the time the petition is served upon the person and the person's guardian. The court clerk shall provide copies of any court orders necessary for the designated crisis responder to provide notice to the tribe or Indian health care provider under this section. Notification under this section is subject to any federal and state laws and regulations including the requirements in RCW 70.02.230 (2)(ee) and (3) and shall be made in person or by telephonic or electronic communication to the tribal contact listed in the authority's tribal crisis coordination plan.
[ 2024 c 209 s 11; 2023 c 433 s 6; 2022 c 210 s 5; 2021 c 264 s 1. Prior: 2020 c 302 s 13; (2020 c 302 s 12 expired January 1, 2021); 2020 c 256 s 302; 2020 c 5 s 2; 2019 c 446 s 4; 2018 c 291 s 4; 2016 sp.s. c 29 s 210; 2015 c 250 s 3; 2011 c 148 s 5; 2007 c 375 s 7; 1998 c 297 s 8; 1997 c 112 s 8; 1984 c 233 s 1; 1979 ex.s. c 215 s 9; 1975 1st ex.s. c 199 s 3; 1974 ex.s. c 145 s 8; 1973 1st ex.s. c 142 s 20.]
Notes:
Expiration date—2024 c 209 ss 11, 13, 23, and 26: "Sections 11, 13, 23, and 26 of this act expire July 1, 2026." [ 2024 c 209 s 39.]
Expiration date—2023 c 433 ss 6, 8, and 10: "Sections 6, 8, and 10 of this act expire July 1, 2026." [ 2023 c 433 s 24.]
Expiration date—2022 c 210 ss 5, 12, 17, and 23: "Sections 5, 12, 17, and 23 of this act expire July 1, 2026." [ 2022 c 210 s 32.]
Expiration date—2021 c 264 ss 1, 3, 6, 8, 10, 14, 31, and 33: "Sections 1, 3, 6, 8, 10, 14, 31, and 33 of this act expire July 1, 2026." [ 2021 c 264 s 35.]
Expiration date—2020 c 302 ss 12, 15, 25, 31, 33, 35, 38, 54, 75, 82, 85, 88, and 91: "Sections 12, 15, 25, 31, 33, 35, 38, 54, 75, 82, 85, 88, and 91 of this act expire January 1, 2021." [ 2020 c 302 s 106.]
Effective date—2020 c 302 ss 13, 16, 19-23, 26, 32, 34, 36, 39, 55, 59, 76, 83, 86, 89, and 92: "Sections 13, 16, 19 through 23, 26, 32, 34, 36, 39, 55, 59, 76, 83, 86, 89, and 92 of this act take effect January 1, 2021." [ 2020 c 302 s 107.]
Expiration date—2020 c 302 ss 13, 16, 26, 39, 45, 55, 78, 83, 86, 92, 94, and 97: "Sections 13, 16, 26, 39, 45, 55, 78, 83, 86, 92, 94, and 97 of this act expire July 1, 2026." [ 2020 c 302 s 108.]
Expiration date—2020 c 256 s 302: "Section 302 of this act expires July 1, 2026." [ 2020 c 256 s 501.]
Expiration date—2020 c 5 ss 2 and 4: "Sections 2 and 4 of this act expire July 1, 2026." [ 2020 c 5 s 6.]
Expiration date—2019 c 446 ss 4, 6, 8, 11, 14, 30, 32, 34, 37, 39, and 41: "Sections 4, 6, 8, 11, 14, 30, 32, 34, 37, 39, and 41 of this act expire July 1, 2026." [ 2019 c 446 s 55.]
Expiration date—2018 c 291 ss 4, 7, and 9: "Sections 4, 7, and 9 of this act expire July 1, 2026." [ 2018 c 291 s 20.]
Effective date—2018 c 291 ss 1-4, 6, 7, 9, 11, 12, 13, and 15: See note following RCW 71.05.020.
Effective dates—2016 sp.s. c 29: See note following RCW 71.05.760.
Short title—Right of action—2016 sp.s. c 29: See notes following RCW 71.05.010.
Certification of triage facilities—Effective date—2011 c 148: See notes following RCW 71.05.020.
Findings—Purpose—Construction—Severability—2007 c 375: See notes following RCW 10.31.110.
Captions not law—2007 c 375: See note following RCW 10.77.635.
Effective dates—Severability—Intent—1998 c 297: See notes following RCW 71.05.010.
(1) When a designated crisis responder receives information alleging that a person, as a result of a behavioral health disorder, presents a likelihood of serious harm or is gravely disabled, the designated crisis responder may, after investigation and evaluation of the specific facts alleged and of the reliability and credibility of any person providing information to initiate detention, if satisfied that the allegations are true and that the person will not voluntarily seek appropriate treatment, file a petition for initial detention under this section. Before filing the petition, the designated crisis responder must personally interview the person, unless the person refuses an interview, and determine whether the person will voluntarily receive appropriate evaluation and treatment at an evaluation and treatment facility, crisis stabilization unit, 23-hour crisis relief center, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. As part of the assessment, the designated crisis responder must attempt to ascertain if the person has executed a mental health advance directive under chapter 71.32 RCW. The interview performed by the designated crisis responder may be conducted by video provided that a licensed health care professional or professional person who can adequately and accurately assist with obtaining any necessary information is present with the person at the time of the interview.
(2)(a) A superior court judge may issue a warrant to detain a person with a behavioral health disorder to a designated evaluation and treatment facility, a secure withdrawal management and stabilization facility, or an approved substance use disorder treatment program, for a period of not more than 120 hours for evaluation and treatment upon request of a designated crisis responder whenever it appears to the satisfaction of the judge that:
(i) There is probable cause to support the petition; and
(ii) The person has refused or failed to accept appropriate evaluation and treatment voluntarily.
(b) The petition for initial detention, signed under penalty of perjury, or sworn telephonic testimony may be considered by the court in determining whether there are sufficient grounds for issuing the order.
(c) The order shall designate retained counsel or, if counsel is appointed from a list provided by the court, the name, business address, and telephone number of the attorney appointed to represent the person.
(d) If the court does not issue an order to detain a person pursuant to this subsection (2), the court shall issue an order to dismiss the initial petition.
(3) The designated crisis responder shall then serve or cause to be served on such person and his or her guardian, if any, a copy of the order together with a notice of rights, and a petition for initial detention. After service on such person the designated crisis responder shall file the return of service in court and provide copies of all papers in the court file to the evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program, and the designated attorney. The designated crisis responder shall notify the court and the prosecuting attorney that a probable cause hearing will be held within 120 hours of the date and time of outpatient evaluation or admission to the evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. The person shall be permitted to be accompanied by one or more of his or her relatives, friends, an attorney, a personal physician, or other professional or religious advisor or traditional cultural healer to the place of evaluation. An attorney accompanying the person to the place of evaluation shall be permitted to be present during the admission evaluation. Any other individual accompanying the person may be present during the admission evaluation. The facility may exclude the individual if his or her presence would present a safety risk, delay the proceedings, or otherwise interfere with the evaluation.
(4) The designated crisis responder may notify a peace officer to take such person or cause such person to be taken into custody and placed in an evaluation and treatment facility, secure withdrawal management and stabilization facility, or approved substance use disorder treatment program. At the time such person is taken into custody there shall commence to be served on such person, his or her guardian, and conservator, if any, a copy of the original order together with a notice of rights and a petition for initial detention.
(5) In any investigation and evaluation of an individual under this section or RCW 71.05.153 in which the designated crisis responder knows, or has reason to know, that the individual is an American Indian or Alaska Native who receives medical or behavioral health services from a tribe within this state, the designated crisis responder shall notify the tribe and Indian health care provider whether or not a petition for initial detention or involuntary outpatient treatment will be filed as soon as possible, but no later than three hours from the time the decision is made. If a petition for initial detention or involuntary outpatient treatment is filed, the designated crisis responder must provide the tribe and Indian health care provider with a copy of the petition, together with any orders issued by the court and a notice of the tribe's right to intervene as soon as possible, but before the hearing, and no later than 24 hours from the time the petition is served upon the person and the person's guardian. The court clerk shall provide copies of any court orders necessary for the designated crisis responder to provide notice to the tribe or Indian health care provider under this section. Notification under this section is subject to any federal and state laws and regulations including the requirements in RCW 70.02.230 (2)(ee) and (3) and shall be made in person or by telephonic or electronic communication to the tribal contact listed in the authority's tribal crisis coordination plan.
[ 2024 c 209 s 12; 2023 c 433 s 7; 2022 c 210 s 6; 2021 c 264 s 2. Prior: 2020 c 302 s 14; (2020 c 302 s 12 expired January 1, 2021); 2020 c 256 s 303; 2020 c 5 s 3; 2019 c 446 s 5; 2018 c 291 s 5; 2016 sp.s. c 29 s 211; 2016 sp.s. c 29 s 210; 2015 c 250 s 3; 2011 c 148 s 5; 2007 c 375 s 7; 1998 c 297 s 8; 1997 c 112 s 8; 1984 c 233 s 1; 1979 ex.s. c 215 s 9; 1975 1st ex.s. c 199 s 3; 1974 ex.s. c 145 s 8; 1973 1st ex.s. c 142 s 20.]
Notes:
Effective date—2024 c 209 ss 12, 14, 24, and 27: "Sections 12, 14, 24, and 27 of this act take effect July 1, 2026." [ 2024 c 209 s 40.]
Effective date—2023 c 433 ss 7, 9, and 11: "Sections 7, 9, and 11 of this act take effect July 1, 2026." [ 2023 c 433 s 25.]
Effective date—2022 c 210 ss 6, 13, 18, and 24: "Sections 6, 13, 18, and 24 of this act take effect July 1, 2026." [ 2022 c 210 s 33.]
Effective date—2021 c 264 ss 2, 4, 7, 9, 11, 15, 32, and 34: "Sections 2, 4, 7, 9, 11, 15, 32, and 34 of this act take effect July 1, 2026." [ 2021 c 264 s 36.]
Expiration date—2020 c 302 ss 12, 15, 25, 31, 33, 35, 38, 54, 75, 82, 85, 88, and 91: "Sections 12, 15, 25, 31, 33, 35, 38, 54, 75, 82, 85, 88, and 91 of this act expire January 1, 2021." [ 2020 c 302 s 106.]
Effective date—2020 c 302 ss 14, 17, 27, 40, 46, 56, 79, 84, 87, 93, 95, and 98: "Sections 14, 17, 27, 40, 46, 56, 79, 84, 87, 93, 95, and 98 of this act take effect July 1, 2026." [ 2020 c 302 s 109.]
Effective date—2020 c 256 s 303: "Section 303 of this act takes effect July 1, 2026." [ 2020 c 256 s 502.]
Effective date—2020 c 5 ss 3 and 5: "Sections 3 and 5 of this act take effect July 1, 2026." [ 2020 c 5 s 7.]
Effective date—2019 c 446 ss 5, 7, 9, 12, 15, 31, 33, 35, 38, 40, and 42: "Sections 5, 7, 9, 12, 15, 31, 33, 35, 38, 40, and 42 of this act take effect July 1, 2026." [ 2019 c 446 s 56.]
Effective date—2018 c 291 ss 5, 8, and 10: "Sections 5, 8, and 10 of this act take effect July 1, 2026." [ 2018 c 291 s 19.]
Effective dates—2016 sp.s. c 29: See note following RCW 71.05.760.
Short title—Right of action—2016 sp.s. c 29: See notes following RCW 71.05.010.
Certification of triage facilities—Effective date—2011 c 148: See notes following RCW 71.05.020.
Findings—Purpose—Construction—Severability—2007 c 375: See notes following RCW 10.31.110.
Captions not law—2007 c 375: See note following RCW 10.77.635.
Effective dates—Severability—Intent—1998 c 297: See notes following RCW 71.05.010.
Notes of Decisions
Cited in 95
cases (16 in the last 5 years), 1976–2026 · leading case: Matter of Harris
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
In re the Detention of C.W. (2002)
“2d at 281, 287 (requiring judicial finding of “probable dangerousness” before a 72- *278 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wn.”
In Re Detention of CW (2002)
“2d 109 (requiring judicial finding of "probable dangerousness" before a 72 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wash.”
Volk v. DeMeerleer (2016)
“3d at 440, 442 ; see also RCW 71.05.150 (defining involuntary commitment procedures for mentally disabled persons presenting a likelihood of serious harm).”
In Re The Detention Of: S.e. (2017)
“RCW 71.05.150, .180. For this detention period to commence, a designated mental health professional must first receive and investigate allegations that a person, “as a result of a mental disorder,” “presents a likelihood of serious harm” or “is gravely disabled.”
In re the Detention of V.B. (2001)
“RCW 71.05.150(2), (5). 3 If the CDMHP deter *962 mines that the detainee is mentally ill and dangerous or gravely disabled, the CDMHP may place the detainee in emergency custody in an evaluation and treatment facility for not more than 72 hours.”
Luchtel v. Hagemann (2010)
“See Wash. Rev.Code § 71.05.150(4) (2006) (current version at Wash.”
Heller v. Doe Ex Rel. Doe (1993)
“1992) (mental retardation and mental illness); Wash. Rev. Code § 71.05.150 et seq. (1992 and Supp.”
Diamond v. Cross (1983)
“150, that there be no "course of proceeding ... specifically pointed out by statute", satisfied here.”
In Re Detention of As (1999)
“RCW 71.05.150. RCW 71.05.160 requires: If a person is involuntarily placed in an evaluation and treatment facility pursuant to RCW 71.”
State v. Lowrimore (1992)
“RCW 71.05.150 provides in pertinent part: A peace officer may, .”
In re the Detention of Johnson (2014)
“Under RCW 71.05.150, a DMHP may initiate a nonemergency detention through a summons procedure.”
— Wash. Rev. Code § 71.05.150(1) — 19 cases
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
In Re The Detention Of: S.e. (2017)
“RCW 71.05.150, .180. For this detention period to commence, a designated mental health professional must first receive and investigate allegations that a person, “as a result of a mental disorder,” “presents a likelihood of serious harm” or “is gravely disabled.”
Matter of Detention of As (1998)
In Re The Detention Of: K.r. (2016)
— Wash. Rev. Code § 71.05.150(1)(a) — 7 cases
In Re Detention of Petersen (1999)
Pierce County v. State (2008)
In Re Detention of Keeney (2007)
In Re Detention of As (1999)
“RCW 71.05.150. RCW 71.05.160 requires: If a person is involuntarily placed in an evaluation and treatment facility pursuant to RCW 71.”
In Re Detention of Turay (1999)
— Wash. Rev. Code § 71.05.150(1)(a)(i) — 2 cases
Volk v. DeMeerleer (2016)
“3d at 440, 442 ; see also RCW 71.05.150 (defining involuntary commitment procedures for mentally disabled persons presenting a likelihood of serious harm).”
Volk v. DeMeerleer (2016)
— Wash. Rev. Code § 71.05.150(1)(b) — 4 cases
Pierce County v. State (2008)
Pierce County v. State (2008)
State v. Lowrimore (1992)
“RCW 71.05.150 provides in pertinent part: A peace officer may, .”
— Wash. Rev. Code § 71.05.150(2) — 17 cases
In re the Detention of C.W. (2002)
“2d at 281, 287 (requiring judicial finding of “probable dangerousness” before a 72- *278 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wn.”
In Re Detention of CW (2002)
“2d 109 (requiring judicial finding of "probable dangerousness" before a 72 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wash.”
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
Spencer v. King County (1984)
In re the Detention of V.B. (2001)
“RCW 71.05.150(2), (5). 3 If the CDMHP deter *962 mines that the detainee is mentally ill and dangerous or gravely disabled, the CDMHP may place the detainee in emergency custody in an evaluation and treatment facility for not more than 72 hours.”
— Wash. Rev. Code § 71.05.150(2)(a) — 9 cases
In Re The Detention Of: S.e. (2017)
“RCW 71.05.150, .180. For this detention period to commence, a designated mental health professional must first receive and investigate allegations that a person, “as a result of a mental disorder,” “presents a likelihood of serious harm” or “is gravely disabled.”
In re the Detention of Johnson (2014)
“Under RCW 71.05.150, a DMHP may initiate a nonemergency detention through a summons procedure.”
Volk v. DeMeerleer (2014)
State v. Carneh (2009)
In Re Detention Of: P.p. (2018)
— Wash. Rev. Code § 71.05.150(3) — 1 case
Harmon v. McNutt (1978)
— Wash. Rev. Code § 71.05.150(4) — 9 cases
Luchtel v. Hagemann (2010)
“See Wash. Rev.Code § 71.05.150(4) (2006) (current version at Wash.”
In re the Detention of D.W. (2014)
In re the Detention of V.B. (2001)
“RCW 71.05.150(2), (5). 3 If the CDMHP deter *962 mines that the detainee is mentally ill and dangerous or gravely disabled, the CDMHP may place the detainee in emergency custody in an evaluation and treatment facility for not more than 72 hours.”
State v. Lowrimore (1992)
“RCW 71.05.150 provides in pertinent part: A peace officer may, .”
State v. Mason (1989)
— Wash. Rev. Code § 71.05.150(4)(b) — 12 cases
In re the Detention of V.B. (2001)
“RCW 71.05.150(2), (5). 3 If the CDMHP deter *962 mines that the detainee is mentally ill and dangerous or gravely disabled, the CDMHP may place the detainee in emergency custody in an evaluation and treatment facility for not more than 72 hours.”
In Re Detention of CW (2002)
“2d 109 (requiring judicial finding of "probable dangerousness" before a 72 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wash.”
State v. Dempsey (1997)
State v. Lowrimore (1992)
“RCW 71.05.150 provides in pertinent part: A peace officer may, .”
In re the Detention of C.W. (2002)
“2d at 281, 287 (requiring judicial finding of “probable dangerousness” before a 72- *278 hour evaluation and treatment summons may be issued even though this finding is not required by RCW 71.05.150). See also In re Det. of Chorney, 64 Wn.”
— Wash. Rev. Code § 71.05.150(5) — 2 cases
In re the Detention of V.B. (2001)
“RCW 71.05.150(2), (5). 3 If the CDMHP deter *962 mines that the detainee is mentally ill and dangerous or gravely disabled, the CDMHP may place the detainee in emergency custody in an evaluation and treatment facility for not more than 72 hours.”
In Re Detention of VB (2001)
— Wash. Rev. Code § 71.05.150(l)(a) — 10 cases
Volk v. DeMeerleer (2016)
“3d at 440, 442 ; see also RCW 71.05.150 (defining involuntary commitment procedures for mentally disabled persons presenting a likelihood of serious harm).”
In re the Detention of Turay (1999)
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
In Re The Detention Of: S.e. (2017)
“RCW 71.05.150, .180. For this detention period to commence, a designated mental health professional must first receive and investigate allegations that a person, “as a result of a mental disorder,” “presents a likelihood of serious harm” or “is gravely disabled.”
Pierce County v. State (2008)
— Wash. Rev. Code § 71.05.150(l)(b) — 1 case
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
— Wash. Rev. Code § 71.05.150(l)(c) — 3 cases
Matter of Harris (1982)
“Petitioner claims the summons procedure for involuntary civil commitment under RCW 71.05.150 violates the due process clause of the federal constitution.”
D.A.H. v. Seattle Times Co. (1996)
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