Paugh v. Henrico Area Mental Health & Developmental Servs.Annotate this Case
Michael Paugh was involuntarily committed after a hearing by a special justice. Paugh appealed. After another hearing, the circuit court found that the involuntary commitment order was valid and denied Paugh's appeal. Paugh again appealed, arguing primarily that the circuit court erred in using the date that the special justice entered the order committing him as the date upon which to evaluate the evidence on his appeal rather than the date of the circuit court hearing. The Supreme Court reversed, holding (1) the circuit court used the incorrect date in this case because the court was statutorily required to determine whether Paugh met the requirements for involuntary commitment on the date of the circuit court hearing; and (2) the evidence was insufficient to commit Paugh as of the date of the circuit court hearing.