This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Respondent was admitted to Memorial Medical Hospital in Las Cruces, New Mexico, after attempting suicide by setting his trailer on fire while inside. The State filed a petition to commit the Respondent to the New Mexico Behavioral Health Institute for thirty days, supported by an affidavit from a psychiatric nurse practitioner who had been the Respondent's primary treating physician since admission (paras 2-3).
Procedural History
- District Court of Doña Ana County: Ordered the involuntary commitment of the Respondent for evaluation and treatment for no more than thirty days (para 7).
Parties' Submissions
- Appellant: Argued that the State needed to prove the unavailability of a physician to prepare the initial screening report, and challenged the sufficiency of evidence regarding the likelihood of benefiting from treatment and the least drastic means principle (paras 4, 6).
- Appellee: Asserted that the psychiatric nurse practitioner was qualified to prepare the screening report and testify, and that the evidence supported the commitment (paras 5, 7).
Legal Issues
- Whether the district court was permitted to accept the screening report and testimony of a psychiatric nurse practitioner without evidence documenting the unavailability of a physician (para 8).
- Whether there was sufficient evidence to support the district court's findings for a thirty-day commitment (para 19).
Disposition
- The Court of Appeals affirmed the district court's order for involuntary commitment (para 24).
Reasons
Per Yohalem J. (Bogardus and Medina JJ. concurring):
The court found that the statutory language allowed for flexibility in who could prepare the screening report, emphasizing the need for a qualified professional rather than strictly a physician. The court interpreted the statute as allowing a mental health professional to prepare the report if a physician was unavailable, without requiring the State to prove unavailability (paras 10-18). The court also found sufficient evidence to support the district court's findings that the Respondent needed treatment, was likely to benefit from it, and that the commitment was the least drastic means, based on the testimony regarding the Respondent's condition and behavior (paras 20-23).