In this appeal, Beeson challenged the sufficiency of evidence to support one of the criteria for continued confinement under the mentally disordered offender (MDO) law; namely that his mental disorder could not be kept in remission without treatment. During the hearing on the petition to extend Beesons commitment, the treating psychiatrist testified that Beeson failed to acknowledge his mental illness, and therefore did not have a relapse prevention plan. He also refused to attend therapy. The court rejected appellants argument, finding that a reasonable jury could have relied on the treating physicians testimony and found that Beeson failed to follow his treatment plan. The trial court also did not err when it denied appellants request to instruct the jury that it should presume that appellant was not an MDO for purposes of the proceeding. While appellant was entitled under the MDO law to proof beyond a reasonable doubt, he was not entitled to the additional safeguards afforded to criminal defendants under the Fourteenth Amendment, including a presumption against involuntary commitment.
Case Summaries