Probate court order requiring respondent to receive involuntary mental health treatment; A “person requiring treatment” under MCL 330.1401(1)(a) & (c); The procedure & content requirements for a petition for mental health treatment; MCL 330.1434(2)-(4); Notice requirements; MCL 330.1453; MCR 5.734; Consultation with counsel; MCL 330.1454(1); Counsel requirements; MCL 330.1454(7)-(9); Prejudice

The court held that the probate court did not err by finding respondent to be a “person requiring treatment” and ordering him to receive involuntary mental health treatment. The probate court entered the order on the basis of his mental illness. On appeal, the court rejected his argument that the probate court erred when it conducted a hearing on a petition for mental health treatment that did not set forth sufficient facts. It noted that the social worker, G, “detailed how she personally observed respondent’s paranoid and somatic” delusions, and “expressed concern that respondent could inflict unintentional harm and lacked the ability to maintain safety.” In addition, her petition included “two clinical certificates, one of which was completed by a psychiatrist.” Each clinical certificate “included facts that supported each doctor’s findings regarding respondent and their conclusions that he required treatment for his mental illness.” As such, the petition “complied with the requirements set forth under MCL 330.1434.” The court also rejected his claim that the probate court failed to address whether he received notice and whether his attorney properly consulted with him in a meaningful way before the hearing. It found that G personally served him with the notice “two days before the hearing on the petition for mental health” treatment, and that he “was aware of the hearing because” one of the doctors testified that respondent did not want to attend. Further, “respondent’s appointed counsel attended the hearing and did not object to, or disagree with, the probate court’s conclusion that respondent received notice of the hearing.” Finally, although the probate court erred “when it did not confirm on the record that appointed counsel consulted with respondent about the petition for mental health treatment and related hearing or require respondent’s appointed counsel to file the certificate required under” MCL 330.1454(9), this error did not “in itself demonstrate prejudice to respondent.” He failed to show “how he might have been prejudiced by the alleged failure of his counsel to consult with him as required by the statute.” Affirmed.