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Civil Practice – Involuntary Commitment – Criminal Practice – Danger to Others – Insufficient Findings (access required)

In re Church Even though there was testimony suggesting respondent may have been responsible for his wife’s shooting death, the trial court made no finding that respondent had committed a homicide in the relevant past, had actually inflicted or threatened to inflict serious bodily harm on any person at any time, or would probably behave in such a way in the future. Thus, the trial court failed to make the findings required to establish that respondent is dangerous to others under G.S. § 122C-3(11)b. We reverse the order involuntarily committing respondent.

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