In Re The Detention Of A.O.

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
IN THE MATTER OF THE
DETENTION OF:
A.O.,
Petitioner.
No. 84670-1-I
DIVISION ONE
UNPUBLISHED OPINION
FELDMAN, J. — After a bench trial, the court concluded that A.O. presented a
likelihood of serious harm to others and was gravely disabled and involuntarily committed
her for 14 days. A.O. asserts that she had a constitutional right to have a jury determine
whether she had a mental illness justifying a 14-day involuntary commitment. 	We
disagree.
This court rejected A.O.’s argument in In re Detention of S.E., 199 Wn. App. 609,
611, 400 P.3d 1271 (2017). We confirmed S.E.’s holding that there is no right to a jury
trial in a hearing on a 14-day involuntary commitment petition in In re Detention of T.C.,
11 Wn. App. 2d 51, 59-60, 450 P.3d 1230 (2019).
A.O. 	argues 	that 	S.E. 	erred 	in 	its 	analysis 	of 	whether 	an 	individual 	is
constitutionally entitled to a jury trial under article I, section 21 of the Washington

No. 84670-1-I/2
2
Constitution. See S.E., 199 Wn. App. at 614-15. Because A.O. advances no novel theory
as to why our analysis in S.E. is incorrect, we decline to overrule its holding.
Affirmed.
WE CONCUR: