State v. T. L. — Involuntary Commitment Under Expanded Chronic Mental Illness Criteria Affirmed; Prior Expanded-Criteria Hospitalizations Count Toward Two-Hospitalization Prerequisite
The Oregon Court of Appeals affirmed a 180-day involuntary commitment under the expanded chronic mental illness criteria of former ORS 426.005(1)(f)(C), holding as a matter of statutory interpretation that prior hospitalizations resulting from expanded-criteria commitments count toward the two-hospitalization prerequisite in sub-subparagraph (C)(ii), and that three mental health professionals’ testimony provided sufficient evidence that the patient’s current symptoms substantially resembled those preceding his prior commitments.