State v. Buffum

ARMSTRONG, J.,

dissenting.

ORS 426.100(1) is one of the procedures that the legislature created to protect allegedly mentally ill persons who face involuntary mental commitment and its accompanying massive curtailment of liberty. The required advice of rights is an integral part of the legislature’s attempt “to ensure that *559all allegedly mentally ill persons get the benefit of a full and fair hearing[.]” State v. Allison, 129 Or App 47, 50, 877 P2d 660 (1994). The majority, however, has taken something that the legislature designed as a protection and converted it into a trap. It allows the trial court to give advice about the nature of the proceeding that is at best a half-truth and that, in context, is positively misleading. Because I cannot join the majority in destroying what the legislature has done, I dissent.

The applicable statutes clearly establish the issues at an involuntary mental commitment proceeding: before it may involuntarily commit a person, the trial court must find, by clear and convincing evidence, that the person is “mentally ill.” ORS 426.130(l)(b). That does not mean, however, that the court need find only that the person suffers from a mental disorder, as the common meaning of the phrase would suggest. Rather, the statutes give that phrase additional meanings that are essential for understanding the issues that the court must decide. To find a person “mentally ill,” the court must find not only that the person suffers from a mental disorder but also that the person is either “[d]angerous to self or others,” ORS 426.005(l)(d)(A) or “[ulnable to provide for basic personal needs and * * * not receiving such care as is necessary for health and safety.” ORS 426.005(l)(d)(B).1 That is, the statute does not focus merely on the person’s status as mentally ill; rather, in order for the person to be subject to commitment, that status must have had specific results that make the person either dangerous to self or others or unable to provide for him or herself. Knowing that the disease must produce certain results in order to justify commitment is essential to defending a mental commitment case. In many, if not most, of the reported decisions the argument is primarily about whether the person’s conceded mental illness has produced results that would authorize commitment.

In this light, the trial court’s attempt to comply with ORS 426.100(l)(b), which required it to inform appellant of the “nature of the proceedings,” was not simply patently inadequate but pointed appellant in the wrong direction. The *560court told appellant that it was the state’s burden to show “that you are mentally ill, as that expression is defined in the statutes!.]” It made no attempt to tell appellant how the statutes defined the phrase. The conclusion that appellant, and anyone else who was not familiar with the statutes, would draw from the court’s advice is that the issue at the hearing was whether she had a mental illness. She would have no reason to think about the effect that the mental illness had on her relations with others or on herself. The advice, thus, misled appellant about the issues at the hearing and the nature of the defense that she should present.2 To say that that misadvice accurately describes the nature of the proceedings both gives that phrase an unnecessarily crabbed and cramped construction and ignores the legislature’s purpose in adopting it.

Both the normal meanings of the relevant words and the way that courts have used the phrase in similar contexts show that the “nature of the proceedings” must include the essential issues that the court will decide at the hearing. After a pro forma trip to the dictionary, the majority correctly concludes that “the statute required the trial court to advise appellant of the essence or the essential character of the hearing that it was about to conduct.” 166 Or App at 555. However, by giving advice that directed appellant’s attention away from the crucial issues, the trial court failed to explain the nature of the proceedings.

The Supreme Court and we have used “nature of the proceedings” in ways that are consistent with how the legislature used the phrase in ORS 426.100(1)(b). In Dennis v. Employment Div., 302 Or 160, 728 P2d 12 (1986), the Supreme Court responded to an argument that requiring Employment Division hearings referees to inquire fully into *561the facts of each case would be unduly burdensome by pointing out that the referee’s duty was only to ensure that relevant evidence appeared in the record. “The necessary inquiry should be apparent from the nature of the proceedings and the evidence adduced.” 302 Or at 166 (emphasis supplied). Every unemployment compensation hearing, of course, follows essentially the same procedure; the difference in the nature of one proceeding from another lies in the substance of the issues that they consider. The court meant, thus, that the referee can tell from the nature of the proceedings — that is, the issues raised and the evidence presented — how much additional inquiry is necessary. In State v. Sanchez, 160 Or App 182, 188, 981 P2d 361, rev den 329 Or 318 (1999), we agreed with the concurrence that a properly certified interpreter is important for a criminal defendant to understand the nature of a criminal proceeding and that that understanding is essential to a fair disposition of the criminal charges. Thus, the nature of a criminal proceeding includes the issues actually involved, not simply the procedures used. Finally, in Jordan v. Brazier Forest Products, 152 Or App 15, 952 P2d 560 (1998), we held, in discussing the proper appeal route for certain orders in workers’ compensation cases, that that route depended on the “nature of the proceeding,” by which we meant the kinds of issues that were the subject of the order. 152 Or App at 19-20.

In short, the purpose of the statutory requirement that the court give the advice, the dictionary meaning of “nature of the proceedings,” and previous appellate uses of that term all show that, in order to comply with the statute, the trial court must inform the allegedly mentally ill person of the statutory meaning of “mentally ill.” This is not, as the majority suggests, an expression of my policy preferences; it is inherent in the legislature’s policy decision to require the court to give meaningful and realistic advice to an allegedly mentally ill person. The only judicial policy preference involved in this case is the majority’s decision not to enforce the legislature’s decision to require what the majority apparently considers to be a meaningless exercise.

Judge Edmonds agrees that the trial court erred. See State v. Zabransky, 166 Or App 672, 998 P2d 805 (2000) (Edmonds, J., dissenting). However, in his concurrence in *562this case he argues that its error was harmless because appellant actually litigated the issue of whether she was mentally ill under the statutory definition. In essence, he relies on counsel’s presumed advice to make up for the court’s failure to comply with the statute. That argument avoids the responsibility that the legislature expressly places on trial courts to ensure fundamental fairness in a mental commitment proceeding. The court has that responsibility under the statute whether or not due process would require precisely the same result.

As we pointed out in Allison, the requirement that the court give the advice is one of the procedures that legislature developed in order to ensure that there will be a full and fair hearing before anyone loses his or her liberty by an involuntary mental commitment. If the legislature had thought it sufficient to rely on counsel to give that information, it would not have needed to require the court to advise the person of anything other than the right to counsel. Instead of that approach, however, the legislature relied on the court, independently of any assistance from counsel, to inform the person of the rights that the statute lists. Counsel’s advice and actions at trial are irrelevant both to whether the court has fulfilled its duty and to whether the court’s failure requires reversal. The error simply cannot be harmless.

In Allison the appellant, who was represented by counsel, stipulated to an involuntary commitment. We nevertheless reversed the order of commitment on the ground that the court had not given the required advice. We did not suggest that counsel’s active involvement in the proceeding, including in the appellant’s decision to stipulate to commitment, was relevant to our disposition of the case.

In Grellert, the advice that the trial court gave was generally adequate, but it failed to tell the appellant of his right to subpoena witnesses. We stated that the “court’s advice of rights here was not complete and, therefore, appellant did not receive that benefit. Accordingly, we remand this case for further proceedings.” Grellert, 144 Or App at 203 (emphasis supplied). Although, as the briefs show, the appellant was represented by counsel, we reversed the commitment without concerning ourselves with whether counsel *563might have already given him the missing information or what actually happened at the hearing.3 The statute requires that the court give the advice. Judge Edmonds’ suggestion that the court’s failure to do so can be harmless error is inconsistent with that requirement.4

For these reasons, I respectfully dissent from the majority’s decision.

For the purposes of this case I do not need to consider the third ground for commitment, that the person is chronically mentally ill. See ORS 426.005(1)(d)(C).

It is not difficult for a court to give complete and helpful advice. The briefs in State v. Grellert, 144 Or App 201, 925 P2d 161 (1996), show that the trial court in that case told the appellant that

“[t]he purpose of today’s hearing is for me to determine whether or not you are mentally ill. That is, whether or not you suffer from a mental disorder and as a result are unable to prepare for your own basic needs or present a danger to yourself or others.” (Emphasis supplied.)

We described that statement as advising the appellant of the nature of the proceedings. Id. at 203. A similar statement would have been adequate in this case.

The briefs indicate that the appellant in Grellert was not only represented by appointed counsel at the time that the court gave him the inadequate advice, but also had a Ph.D. in biochemistry and had worked for OSHA in California for 18 years, a job that one would expect to give him some understanding of legal procedure.

This situation is analogous to the requirement in Article I, section 11, of the Oregon Constitution, and ORS 136.001(2) that a defendant may waive a jury trial only in writing. We routinely enforce that requirement and reverse convictions without regard to whether the defendant had counsel in the trial court. See, e.g., State v. Huntley, 112 Or App 22, 827 P2d 918 (1992); State v. McDaniel, 96 Or App 337, 772 P2d 951, rev den 308 Or 382 (1989).