In Re RF’s Empirical Analysis
2006
Citation profile
7 state decisions
How this case has been cited
Cited by 7 later decisions — most recently May 2024
7 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Wolfe v. Beal · In Re Commitment of Hutchinson · In re T.J. · In Re JS · In Re Hancock
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Persons Subject to Extended Involuntary Emergency Treatment. — Application for extended involuntary treatment may be made for any person who is being treated pursuant to [50 P.S. § 7302] whenever the facility determines that the need for emergency treatment is likely to extend beyond 120 hours. The application shall be filed forthwith in the court of common pleas, and shall state the grounds on which extended treatment is believed to be necessary (b) Appointment of Counsel and Scheduling of Informal Hearing. — Upon receiving such application, the court of common pleas shall appoint an attorney who shall represent the person unless it shall appear that the person can afford, and desires to have, private representation. Within 24 hours after the application is filed, an informal hearing shall be conducted by a judge or by a mental health review officer and, if practicable, shall be held at the facility. (c)Informal Conference on Extended Emergency Treatment Application. — (1) ... At the conclusion of the review, if the judge or the review officer finds that the person is severely mentally disabled and in need of continued involuntary treatment, he shall so certify. Otherwise, he shall direct that the facility director or his designee discharge the person ... (f) Effect of Certification. — Upon the filing and service of a certification for extended involuntary emergency treatment, the person may be given treatment in an approved facility for a period not to exceed 20 days. (”
1 later decision quote this exact passagee.g. Interest of K.L.S“a person who has been unlawfully committed to a state mental facility has a constitutional right to the destruction of hospital records created as a result of the illegal commitment. Wolfe v. Beal, 477 Pa. 477 , 384 A.2d 1187 (1978). Wolfe’s rationale has been extended to require that court records also be expunged when an illegal commitment occurs; to-wit: To be sure, the question of expungement of court records arising from an illegal commitment was not at issue in Wolfe simply because the lower court’s decision to order such relief was not challenged. However[,] we think it clear that the Court’s reasoning regarding destruction of the hospital records is equally applicable to the issue sub judice. Be they hospital records or court records, the disposi-tive fact is that they originated as a result of an illegal proceeding subsequently declared null and void; and, in either case, their “continued existence [...] pose a threat to [Appellant's reputation.” Under such circumstances, and in the absence of any compelling reason to the contrary offered by the Commonwealth, justice demands that [Appellant be returned to a position as near as possible as that which [she] enjoyed prior to the illegal commitment; namely, an unsullied record.”
1 later decision quote this exact passage“1) Appellant’s stress over divorce proceedings initiated by his wife, as well as her securing exclusive possession of the marital home; 2) Appellant’s searching the internet for data on “How to commit suicide,” and following this by calling a suicide hotline for information on the topic provided on the web site; 3) Appellant’s denial when inquiry was made by police and medical personnel regarding possession of loaded weapons in his home and truck; 4) Appellant’s admission to the hotline operator and medical personnel that he had contemplated suicide; 5) Appellant’s suicide ideation is confirmed by hospital records; and 6) finally, the trial court attributing Appellant with a lack of credibility at the [expungement] hearing....”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.