In re Robledo
| Decision Date | 06 June 2000 |
| Docket Number | No. CX-99-2108.,CX-99-2108. |
| Citation | 611 N.W.2d 67 |
| Parties | In the Matter of Manuel ROBLEDO. |
| Court | Minnesota Court of Appeals |
Allan R. Poncin, Minneapolis, for appellant Robledo.
Mike Hatch, Attorney General, St. Paul, for respondent state.
Amy Klobuchar, Hennepin County Attorney, Carolyn A. Peterson, Thomas G. Lavelle, Assistant County Attorneys, Minneapolis, for respondent county.
Considered and decided by HARTEN, Presiding Judge, LANSING, Judge, and DAVIES, Judge.
On appeal from recommitment as a mentally ill person, Manuel Robledo contends that the district court violated Minn.Stat. § 253B.13, subd. 1 (1998), by allowing petitioners to use consecutive-recommitment procedures even though his original commitment had expired. Because the statutory procedures for consecutive recommitment require a new petition, hearing, and determination to be completed before the expiration of any existing commitment order, we reverse.
Manuel Robledo was committed as a mentally ill person to the Minneapolis Veterans' Affairs Medical Center and the Anoka-Metro Regional Treatment Center (AMRTC) on July 1, 1998. At a review hearing the following December, the court continued Robledo's commitment through September 30, 1999, under Minn.Stat. §§ 253B.12, .13 (1998).
On September 29, 1999, one day before Robledo's commitment was due to expire, Hennepin County and AMRTC (petitioners) filed three petitions. One petition requested recommitment, the second requested continued administration of neuroleptic drugs (a Jarvis order), and the third requested an emergency extension of the current orders until completion of a hearing. The recommitment petition was accompanied by the required examiner's statement from Robledo's treating psychologist.
The court issued an ex parte emergency order continuing the December 1998 orders. Robledo challenged the ex parte order at his consecutive-recommitment hearing, contending that the order violated the statutory recommitment provisions and his constitutional rights to notice, legal representation, and a hearing within 72 hours of the commitment petition. The court rejected Robledo's arguments and ordered Robledo's continued involuntary institutionalization until September 30, 2000. Robledo appeals the recommitment.
Does Minn.Stat. § 253B.13 (1998) permit the court to temporarily extend an involuntary commitment until completion of a hearing and determination on a petition for consecutive recommitment?
The Minnesota Commitment and Treatment Act provides for an initial commitment period not to exceed six months. Minn.Stat. § 253B.09, subd. 5 (1998). If the person is confined more than 60 days, the act requires the custodial facility to provide a report indicating, among other things, whether the patient is in need of further care and treatment. Minn.Stat. § 253B.12, subd. 1(b) (1998).
The commitment act requires the court to hold a review hearing within 14 days of receipt of the report and before the initial commitment expires to determine whether there is clear and convincing evidence that the patient requires continued commitment. Id., subds. 2a, 4 (1998). If the court concludes that continued commitment is required, it may order the continued commitment for a specific time, not to exceed 12 months. Minn.Stat. § 253B.13, subd. 1 (1998).
The statute prohibits a further extension of commitment beyond the expiration of the continued commitment unless specific procedures are followed:
At the conclusion of the prescribed period, commitment may not be continued unless a new petition is filed pursuant to section 253B.07 and hearing and determination made on it.
Id. (emphasis added). Consecutive recommitment after expiration of a continued commitment incorporates the petition requirement of an initial commitment hearing but is subject to the statutory standard of proof for the continued commitment after a review hearing, rather than the standard applicable to an initial commitment. Id.
The standard of proof for an initial commitment is higher than the standard of proof for continued commitment after a review hearing. Compare Minn.Stat. § 253B.02, subd. 13 (1998) (), with Minn.Stat. § 253B.12, subd. 4 ().
Whether the lower consecutive-recommitment standard of proof applies to Robledo's commitment depends on whether the petitioners complied with the statutory conditions governing consecutive recommitment. The petitioners argue that the language of section 253B.13, subdivision 1, stating that "commitment may not be continued unless a new petition is filed pursuant to section 253B.07 and hearing and determination made on it" need not be strictly applied and that the district court may temporarily extend a continued-commitment order. Robledo, on the other hand, argues that such an extension violates the statute. We agree with Robledo's interpretation of the statute.
Our function in interpreting statutes is to ascertain and effectuate legislative intent. Minn.Stat. § 645.16 (1998). When a statute is free from ambiguity, we look only at its plain language. Id.; Tuma v. Commissioner of Econ. Sec., 386 N.W.2d 702, 706 (Minn.1986). Plain meaning takes into account the whole structure of the statute and the context of the challenged language. King v. St. Vincent's Hosp., 502 U.S. 215, 221, 112 S.Ct. 570, 574, 116 L.Ed.2d 578 (1991). We presume plain and unambiguous statutory language manifests legislative intent. Lenz v. Coon Creek Watershed Dist., 278 Minn. 1, 9, 153 N.W.2d 209, 216 (1967).
To apply petitioners' statutory interpretation, we would have to disregard the plainly stated requirement that commitment may not be continued beyond the date specified in the continued-commitment order after the review hearing "unless a new petition is filed pursuant to section 253B.07 and hearing and determination made on it." Minn.Stat. § 253B.13, subd. 1 (emphasis added).
The plain meaning and significance of this language is confirmed by its context and function in the statutory commitment process. The legislature has specified that a mentally ill person may be subject to an involuntary commitment—initially, and after a review hearing, and even after consecutive recommitment—only for a determinate length of time. Indeterminate sentences are reserved for defined categories of patients who pose a danger to society, such as those committed as mentally ill and dangerous, sexually dangerous, or with sexual psychopathic personalities. See Minn.Stat. §§ 253B.18, subd. 3 (1998) (); .185, subd. 1 (Supp.1999) ().
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