## Facts

- Sharon Suzuki was involuntarily committed to a psychiatric facility in Hawaii and sought habeas relief, declaratory relief, and an injunction challenging Hawaii’s civil commitment procedures.
- The district court certified a class of all present and future persons confined under the challenged Hawaii mental health statutes.
- After earlier litigation prompted statutory revisions, Hawaii enacted revised commitment provisions (Haw. Rev. Stat. ch. 334 (1976)), and plaintiffs challenged specified portions of the revised law.
- With no material factual disputes, both sides moved for summary judgment; the district court ruled that four provisions of the revised statute were unconstitutional.
- The state appealed the merits decision; it also appealed an order denying a stay of an attorneys’ fees award that had already been paid.

## Issues

1. Whether due process permits involuntary commitment based on dangerousness to “any property.”
2. Whether due process requires a showing of imminent danger before involuntary commitment.
3. Whether the commitment scheme violated the privilege against self-incrimination in civil commitment proceedings.
4. Whether due process requires the state to prove commitment elements beyond a reasonable doubt.
5. Whether the state’s appeal from the denial of a stay of attorneys’ fees was moot after payment.

## Decision

- Affirmed in part and reversed in part the district court’s merits judgment.
- Held unconstitutional the statute’s authorization of commitment based on dangerousness to “any property.”
- Held unconstitutional the statute’s failure to require a showing of imminent danger before commitment.
- Reversed the district court’s rulings that the statute violated the privilege against self-incrimination and that due process required proof beyond a reasonable doubt.
- Dismissed the attorneys’ fees stay appeal as moot because the fees had already been paid and the merits judgment was affirmed in part.

## Legal Principles

- Civil commitment must be limited by substantive due process; confinement cannot rest on overly broad dangerousness criteria that do not justify the severe liberty deprivation.
- Due process requires a close connection between current condition and the need for confinement; a finding of danger must include a temporal requirement of imminence to avoid commitment based on speculative risk.
- Civil commitment proceedings are civil in nature; absent statutory compulsion creating constitutionally impermissible consequences, the commitment scheme does not necessarily violate the privilege against self-incrimination.
- Due process does not require proof beyond a reasonable doubt in civil commitment; a clear and convincing evidence standard is constitutionally sufficient.
- An appeal is moot where the challenged fee-related order has been fully executed by payment and no effective relief remains available.

## Conclusion

The court narrowed permissible grounds for involuntary civil commitment by barring commitment based on danger to property and requiring imminent dangerousness, while holding that civil commitment does not require criminal-procedure protections for self-incrimination or a reasonable-doubt burden of proof.


Suzuki v. Yuen, 617 F.2d 173 (9th Cir. 1980)