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Civil Practice – Involuntary Commitment – Danger to Self – Suicide Attempts

The trial court’s explicit finding that respondent’s “second suicide attempt” was a “fact[] supporting involuntary commitment” did not state exactly when the suicide attempts occurred. Nevertheless, the evidence established that the first and second attempts occurred within six months and three weeks of the hearing, respectively. Thus, the trial court’s finding could only refer to the attempts occurring in July and December 2021.

We affirm the trial court’s involuntary commitment order.

The trial court’s remaining findings are sufficient to demonstrate that there is a reasonable probability of suicide unless adequate treatment is given. The trial court found that respondent continued to suffer from “[d]elusional thinking (‘soul not connected to body; others out to get him, etc.’),” and was noncompliant with medication. Both treating psychiatrist Dr. Sandra Brown and respondent himself testified that these thoughts and his prior lack of effective medication are what drove him to attempt suicide.

The trial court’s findings, viewed in light of the uncontradicted evidence and admitted facts that underlie the findings, demonstrate and support the trial court’s ultimate findings that respondent was dangerous to himself given his recent suicide attempts and the continuation of those circumstances that led to the attempts. Further, a report from Dr. Shi Xun Fang, who examined respondent, stated that respondent’s continued delusions and refusal to engage in treatment, when considered alongside “the severity and lethality of [respondent’s] recent [suicide] attempt,” placed him “at high risk of harm to self.”

In re C.H. (Lawyers Weekly No. 012-577-22, 12 pp.) (Lucy Inman, J.) Appealed from Durham County District Court (Pat Evans, J.) Hilary Ventura for the state; Katy Dickinson-Schultz and Glenn Gerding for respondent. 2022-NCCOA-923

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