In re Commitment of E.F.
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The Supreme Court affirmed the judgment of a panel of the court of appeals dismissing an appeal in this temporary commitment case on the grounds that the appeal was moot, holding that "public interest exception" to mootness applied.
After a hearing, the trial court found E.F. was gravely disabled and entered a temporary commitment order allowing for her emergency detention. While E.F.'s appeal was pending, the commitment order expired. The court of appeals dismissed E.F.'s appeal as moot, interpreting T.W. v. St. Vincent Hospital & Healthcare Center, Inc., 121 N.E.3d 1039 (Ind. 2019), as disfavoring the practice of applying the public interest exception except in "rare circumstances." The Supreme Court reversed, holding that E.F. should have the opportunity to make certain arguments before the court of appeals.
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