In re Pima County Mental Health No. 20200860221
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The Supreme Court held that in determining whether a petition for court-ordered treatment complies with statutory requirements, courts may consider contents of an extrinsic document attached to an affidavit if the affidavit specifically incorporates the attachment by reference.
The trial court found that G.B. was persistently or actually disabled and ordered treatment for one year. The court of appeals vacated the trial court's order on the grounds that involuntary treatment proceedings require strict statutory compliance and that two affidavits submitted by G.B. failed to comply with Ariz. Rev. Stat. 36-533(B). The Supreme Court vacated the court of appeals' opinion and affirmed the order of the trial court, holding that that there was no fundamental, prejudicial error in this case because the trial court's error did not deprive G.B. of a fair opportunity to oppose the petition for involuntary treatment or to otherwise receive a fair hearing.
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