This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- Respondent Heather Lewis voluntarily sought treatment for suicidal thoughts at Eastern New Mexico Medical Center and requested admission to Sunrise Mental Health for treatment. Due to her history of mental health issues, the State of New Mexico petitioned for her involuntary commitment to the New Mexico Behavioral Health Institute (NMBHI) for thirty days. The district court ordered her commitment, which was to commence upon filing the order and remain in effect until she could be transported to NMBHI. However, due to a lack of available beds, her transfer was delayed, leading to a motion for extended commitment, which was denied by the district court due to procedural issues. Lewis was eventually transferred to NMBHI but was released sixty-eight days after the initial commitment order, leading to her appeal.
Procedural History
- District Court of Chaves County: Ordered involuntary commitment of Heather Lewis to NMBHI for thirty days and denied the State's motion for an extension of that commitment.
Parties' Submissions
- Respondent-Appellant: Argued that the district court exceeded its statutory authority and violated her due process rights by delaying the start of her commitment until transport to NMBHI without the protections required for extending involuntary commitments.
- Petitioner-Appellee: Asserted that the appeal was moot, the arguments were not preserved for appeal, the amendment of the commitment order was in accordance with statutory authority, and even if not, it constituted a valid extension under the law.
Legal Issues
- Whether the district court exceeded its statutory authority by delaying the start date of Respondent's involuntary commitment until her transport to NMBHI.
- Whether the district court's actions constituted a valid extension of Respondent's commitment under the relevant statutes.
Disposition
- The Court of Appeals concluded that the district court exceeded its statutory authority by delaying the start date of Respondent's commitment and reversed and remanded the case for the district court to vacate its order.
Reasons
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The Court of Appeals, with Judges Kristina Bogardus, Jacqueline R. Medina, and Jane B. Yohalem concurring, found that the district court erred in delaying the start of Lewis's commitment until her transport to NMBHI, effectively extending her commitment beyond the statutory thirty-day maximum without adhering to the procedural requirements for such an extension. The court determined that commitment begins upon court order, not transport, and that the procedural safeguards for extending a commitment were not met. The appeal was not moot despite Lewis's release, as the issues presented were of substantial public interest and capable of repetition yet evading review. The court's interpretation of the statutes involved led to the conclusion that the district court's actions were contrary to law, necessitating reversal and remand to vacate the order of commitment (paras 1-24).
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