Table 1

Brief Summary of Selected Commitment Tele-Court Cases

Court CaseStateHolding
United States v. Baker, 45 F.3d 837 (4th Cir. 1995)17North 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)18MontanaThe 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)16OregonAppellate 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)19VirginiaTeleconferencing did not undermine constitutional or statutory rights in the civil commitment of a sexually violent predator.
Doe v. State of Florida (Fla. 2017)15FloridaCivil commitment hearings can only be held virtually if the respondent approves.
People v. Thomas (Cal. Ct. App. 2019)20CaliforniaFailure to object preemptively to videoconferencing forfeits the claim that its use violated rights.