In re Mental Health Actions for A.S.
Annotate this CaseSara Townsend and A.S. were co-workers. Townsend completed an application to initiate a process to seek immediate emergency treatment for A.S., alleging that A.S. was a threat to herself or others. A trial court judge issued a warrant for A.S.’s detention and treatment. Doctors at the hospital where A.S. was subsequently detained, however, determined that there was no cause to continue detaining A.S. and discharged her. Thereafter, the trial judge found Townsend in contempt of court and imposed sanctions. The court of appeals (1) concluded that the trial court lacked statutory authority to find Townsend in indirect civil contempt, but (2) upheld the trial court’s order directing Townsend to pay A.S.’s hospital bill and attorney fees as a legitimate exercise of the trial court’s inherent powers to issue sanctions. The Supreme Court vacated the court of appeals’ opinion and reversed, holding (1) the trial court lacked the statutory authority to find Townsend in contempt and impose sanctions; and (2) Townsend’s actions did not place her under the trial court’s authority to impose sanctions as an inherent power of the judiciary.
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