Cited by

VI; see also In re MH-2008- 000867, -80 ¶¶ 2, 7 (2010) (the Sixth Amendment’s confrontation clause does not apply in involuntary commitment proceedings under Title 36).

See, e.g., Addington v. Texas, 441 U.S. 418, 425 (1979) (“This Court repeatedly has recognized that civil commitment for any purpose constitutes a significant deprivation of liberty that requires due process protection.”); see also In re MH-2008-000867, –81 ¶¶ 8–9 (2010).

When considering telephonic or remote testimony, we determine “whether good cause has been shown for its use.” In re MH-2008-000867, ¶ 11 (2010).

“Involuntary commitment involves a significant curtailment of individual liberty.” In re MH2008-000867, ¶ 13 (2010).

See In re MH2008-000867, -81, ¶ 8 (2010) (“Although civil commitment proceedings pose a potential loss of liberty, they differ from criminal proceedings in many important ways.

Dep’t ¶ 11 (App. 2014); see also In re MH-2008-000867, ¶ 12 (2010) (“’[D]ue process,’ unlike some legal rules, is not a technical conception with a fixed content unrelated to time, place and circumstances.”) (quoting Mathews, 424 U.S. at 334).

See In re MH-2008-000867 , , ¶ 5

Although the orders themselves are moot, we consider the merits of the appeal “because the issue presented is of statewide importance and capable of evading review.” In re MH-2008-000867, ¶ 1 (2010) (citing Coconino Cty.

In evaluating “the specific dictates of due process,” In re MH-2008-000867, courts also consider the following factors: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such 2 The record includes e-mails from the clinical team to Appellant asking him to contact his attorney and providing th

See In re MH-2008-000867, ¶ 1 (2010).

4 We recognize civil commitment proceedings “differ from criminal proceedings” and “should not be constitutionally ‘equated to a criminal prosecution’ because the state is not acting in a punitive manner.” In re MH 2008-000867, -81, ¶ 8 (2010) (quoting Addington v. Texas, 441 U.S. 418, 428 (1979)).

at ¶ 13; In re MH 2006-000749, ¶ 14, see also In re MH-2008-000867, ¶ 4, (stating civil commitment is “a massive curtailment of liberty” and requires due process protection) (internal quotations marks and citation omitted).

In re MH-2008-000867, ¶ 11

1804 , 60 L.Ed.2d 323 (1979); In re MH-2008-000867, -81, ¶ 8 , -08 (2010).

No. JS-7499, , (The right to confront an accuser under the state and federal constitutions "belongs solely to the accused in a criminal prosecution.”); cf. In re MH-2008-000867, , (finding that criminal cases addressing the Confrontation Clause were inapplicable to mental health commitment proceedings because such proceedings are civil).