IN THE MATTER OF J.R.L., Alleged to be Seriously Mentally Impaired, IN THE MATTER OF J.R.L., Alleged to be a Chronic Substa nce Abuser, J.R.L., Respondent - Appellant.
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IN THE COURT OF APPEALS OF IOWA
No. 8-682 / 08-0298
Filed September 17, 2008
IN THE MATTER OF J.R.L.,
Alleged to be Seriously
Mentally Impaired,
IN THE MATTER OF J.R.L.,
Alleged to be a Chronic
Substance Abuser,
J.R.L.,
Respondent-Appellant.
________________________________________________________________
Appeal from the Iowa District Court for Woodbury County, John D.
Ackerman, Judge.
J.R.L. appeals her involuntary commitment under Iowa Code chapters 125
and 229 based on serious mental impairment and chronic substance use.
APPEAL DISMISSED.
Kendra M. Olson, Sioux City, for appellant.
Thomas J. Miller, Attorney General, Gretchen Kraemer, Assistant Attorney
General, Patrick Jennings, County Attorney, and Loan Hensley, Assistant County
Attorney, for appellee State.
Considered by Sackett, C.J., and Miller and Potterfield, JJ.
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POTTERFIELD, J.
I. Background Facts and Proceedings
J.R.L. is a fifty-nine year old medical doctor. She struggles with several
serious medical issues, including cardiac and respiratory issues. The hospital
where Dr. L was receiving asthma treatments contacted her adult children about
seeking an order for involuntary hospitalization.
On January 7, 2008, Dr. L’s two children filed petitions seeking
commitment of their mother based on serious mental impairment and chronic
substance abuse under Iowa Code sections 229.12 and 125.82 (2007). At a
hearing on the issue, Dr. L’s two children and brother testified as to her serious
mental impairment and chronic substance use. On January 17, 2008, the court
found that Dr. L was seriously mentally impaired and a chronic substance abuser
by clear and convincing evidence and ordered Dr. L to outpatient treatment.
As of June 6, 2008, the commitment was discharged because Dr. L had
successfully completed treatment. Dr. L now appeals the decision of the district
court, arguing that the evidence was insufficient to support the findings that she
was seriously mentally impaired and a chronic substance abuser.
II. Merits
One principle of judicial restraint is that courts do not decide cases when
the underlying controversy is moot. Rhiner v. State, 703 N.W.2d 174, 176 (Iowa
2005). “A case is moot if it no longer presents a justiciable controversy because
the issues involved are academic or nonexistent.” Baker v. City of Iowa City, 750
N.W.2d 93, 97 (Iowa 2008). The test to determine if a case is moot is whether an
opinion would be of force or effect in the underlying controversy. Iowa Mut. Ins.
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Co. v. McCarthy, 572 N.W.2d 537, 540 (Iowa 1997). Because Dr. L has been
discharged, our decision would have no effect on the underlying action; thus, the
case is moot.
However, we will consider moot issues on appeal under certain
circumstances. In deciding whether to review a moot issue, we consider four
factors: (1) the private or public nature of the issue; (2) the desirability of an
authoritative adjudication to guide public officials in their future conduct; (3) the
likelihood of the recurrence of the issue; and (4) the likelihood the issue will recur
yet evade appellate review. State v. Hernandez-Lopez, 639 N.W.2d 226, 235
(Iowa 2002).
The Iowa Supreme Court has held that “[t]he procedural aspects of an
involuntary civil commitment hearing are of great public importance.”
In re
T.S., 705 N.W.2d 498, 502 (Iowa 2005) (citing In re M.T., 625 N.W.2d 702, 705
(Iowa 2001)). The Supreme Court exercised its discretion to reach the merits of
the issue presented by the appellants in In re M.T. and In re T.S. because both
were statutory procedural issues that were likely to reoccur. See In re M.T., 625
N.W.2d 702; In re T.S., 705 N.W.2d 498. Dr. L., on the other hand, asks us to
make a finding as to the sufficiency of the evidence, which is very specific to her
case. These particular evidentiary questions are unlikely to reoccur in the same
context. In addition, guidance as to evidentiary matters is already provided by
Iowa Code sections 125.82(4) and 229.12(3) (2007). Dr. L does not claim that
an adjudication would guide public officials in their future conduct, but only that it
would benefit her standing with the medical board.
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Because the only issue on appeal has been rendered moot, we dismiss
the appeal.
APPEAL DISMISSED.
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