Civil Practice – Involuntary Commitment – Danger to Self or Others – Insufficient Showing

In re Smith (Lawyers Weekly No. 012-065-17, 7 pp.) (Douglas McCullough, J.) Appealed from Mecklenburg County District Court (Kimberly Best-Staton, J.) N.C. App. Unpub.

Holding: Although respondent was diagnosed with bipolar disorder “currently manic and psychotic, hostile, yelling, intrusive, paranoid, delusional, grandiose,” neither the evidence nor the trial court’s findings – that respondent (1) would not take her medication, (2) believed she was living in a chlorine-infested apartment, (3) believed she was under surveillance, (4) believed people were trying to kill her, (5) could barely sleep, and (6) believed that hospital staff were giving her medication so that they could move her papers around – were insufficient to support the conclusions that respondent was dangerous to herself and others.

We reverse the involuntary commitment order and remand for further findings.