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Cook v. Steed
Citations: 758 P.2d 906; 84 Utah Adv. Rep. 8; 1988 Utah LEXIS 54; 1988 WL 77170Docket: No. 860055
Court: Utah Supreme Court; June 14, 1988; Utah; State Supreme Court
Plaintiff alleges violation of due process due to his commitment at the Utah State Hospital. His habeas corpus petition was denied by the district court, and he appeals the decision, which is upheld. The plaintiff was arrested on April 4, 1984, after threatening a child with a shotgun, which led to a petition for his commitment to evaluate his competency to stand trial under Utah Code Ann. 77-15-3. Following a ten-day evaluation, the court deemed him mentally ill and ordered a six-month temporary hospitalization. On June 14, 1984, he was found not competent to stand trial and was committed to the hospital until he regained competency. His civil commitment ended on June 18, 1984, but he remained under criminal commitment. By June 20, 1985, the State Hospital reported his ongoing deterioration, prompting a new application for involuntary civil commitment. Following a transfer to Utah County due to the lack of suitable facilities, the court ordered his hospitalization for an indeterminate period on August 8, 1985. Subsequently, criminal charges were dismissed on August 21, 1985, due to his incompetency. Plaintiff filed for habeas corpus on September 12, 1985, arguing lack of initial jurisdiction for the commitment and claiming due process violations due to an alleged 18-month detention without a hearing. However, the record indicates that he was not held without hearings, and the criminal charges were dismissed, rendering this argument moot. He also contended that civil commitment was invalid while under criminal commitment, but the court clarified that statutes do not prohibit civil commitment during criminal proceedings. The court found that criminal proceedings were stayed during his treatment, and all rights were upheld in civil commitment proceedings. After reviewing the case, the court affirmed the lower court's decision, finding no error.