The Rhode Island Supreme Court has dismissed as moot an appeal challenging a lower court's authorization of involuntary outpatient psychiatric treatment and forced medication for a patient identified as G.S.
The case, *In re G.S.* (R.I. 2025), arose from events in September 2024 when G.S. was engaging in increasingly erratic behavior in the community. Scituate police requested a psychiatric evaluation of G.S. at Gateway Healthcare Inc., which resulted in his emergency admission to Rhode Island Hospital.
Dr. Jared Au Yeung, a staff psychiatrist at Rhode Island Hospital, subsequently filed petitions in District Court seeking civil court certification under Rhode Island General Laws § 40.1-5-8(a) and instructions under § 40.1-5-8(m) to treat G.S. against his will.
At a Sept. 27, 2024 hearing, Dr. Au Yeung testified that G.S. had a documented history of schizophrenia, multiple inpatient psychiatric admissions, and previous court-ordered treatment. The psychiatrist described G.S.'s behavior during his hospitalization as argumentative, paranoid, and disruptive, noting that the patient refused recommended treatments.
After his evaluation, Dr. Au Yeung concluded that G.S.'s "continued unsupervised presence in the community would create a likelihood of serious harm by reason of psychiatric illness as manifested by a substantial risk of physical harm to others." This assessment formed the basis for the doctor's petition for involuntary treatment.
G.S. was represented at the District Court hearing by competent counsel from the Office of the Mental Health Advocate. Despite this representation, the District Court issued an amended order certifying G.S. to outpatient treatment, finding him not competent to make informed decisions regarding recommended medications, and consenting to the administration of specific medications.
G.S. appealed the District Court's order to the Rhode Island Supreme Court, arguing that the order was made in plain error and that he was unable to properly prepare for trial. The appeal was assigned case number 2024-359-Appeal and docketed as MH-24-489.
The Rhode Island Supreme Court initially directed both parties to show cause why the issues raised in the appeal should not be summarily decided, a procedural step that allows courts to potentially resolve cases without full briefing when the legal issues are straightforward.
After conducting a careful review of the record and hearing oral arguments from both sides, the Rhode Island Supreme Court concluded that cause had not been shown for continued proceedings. The high court determined that the appeal could be resolved without further briefing or argument.
In its order, the court stated: "After a careful review of the record and oral argument, we are of the opinion that cause has not been shown and that the appeal may be resolved without further briefing or argument. For the reasons set forth herein, the matter before the Court is moot."
The Supreme Court's determination that the case was moot suggests that circumstances changed after the District Court's initial ruling, making the legal questions presented in the appeal no longer relevant or capable of judicial resolution. Courts typically find cases moot when the relief sought is no longer possible or when the underlying circumstances have changed substantially.
While the specific reasons for the mootness determination are not detailed in the available court order, such findings in mental health cases often occur when a patient's condition improves, treatment is completed, or the patient is discharged from care.
The case highlights the complex intersection of individual rights and public safety in involuntary mental health treatment proceedings. Rhode Island's civil commitment statutes allow for court-ordered treatment when a person poses a substantial risk of harm to themselves or others due to mental illness and lacks the capacity to make informed treatment decisions.
The involvement of the Office of the Mental Health Advocate demonstrates Rhode Island's commitment to ensuring that individuals facing involuntary treatment have qualified legal representation. This office specializes in protecting the rights of persons with mental illness in civil commitment and guardianship proceedings.
The dismissal of this appeal as moot means that the underlying legal questions about the District Court's authorization of involuntary treatment and forced medication remain unresolved at the appellate level. Future cases involving similar circumstances will not benefit from Supreme Court guidance on these issues.
The case also underscores the time-sensitive nature of mental health proceedings, where a patient's condition and circumstances can change rapidly, potentially rendering appellate review moot before higher courts can provide definitive legal guidance on important constitutional and statutory questions surrounding involuntary psychiatric treatment.