Videoconferencing of Involuntary Commitment Hearings in the COVID Era

Article Figures & Data

Table 1

Brief Summary of Selected Commitment Tele-Court Cases

Court Case	State	Holding
United States v. Baker, 45 F.3d 837 (4th Cir. 1995)¹⁷	North Carolina (federal case)	The commitment tele-hearing did not violate the rights of a federal prisoner facing involuntary commitment.
In re the Mental Health of LK (Mont. 2008)¹⁸	Montana	The use of microphone muting in involuntary civil commitment was permitted due to disruptive behavior.
In re G.N., 230 Or. App. 249 (Or. Ct. App. 2009)¹⁶	Oregon	Appellate court ruled that lower court abused discretion in denying respondent's request to be physically present without providing a justification.
Shellman v. Commonwealth of Virginia (Va. 2012)¹⁹	Virginia	Teleconferencing did not undermine constitutional or statutory rights in the civil commitment of a sexually violent predator.
Doe v. State of Florida (Fla. 2017)¹⁵	Florida	Civil commitment hearings can only be held virtually if the respondent approves.
People v. Thomas (Cal. Ct. App. 2019)²⁰	California	Failure to object preemptively to videoconferencing forfeits the claim that its use violated rights.