Continuation of involuntary mental health treatment; “Person requiring treatment”; MCL 330.1401(1); MCL 330.1401(1)(b) & (c)

Finding no clear error in the probate “court’s factual findings and no abuse of discretion in its decision to continue the order for involuntary mental health treatment[,]” the court affirmed the probate court’s order denying respondent’s petition for discharge from involuntary mental health treatment. He argued that “clear and convincing evidence did not support the probate court’s decision to continue the order requiring him to engage in involuntary mental health treatment.” He reasoned that the probate “court did not adequately determine that he is a ‘person requiring treatment.’” Respondent pointed out that the probate court’s order “did not specify the particular provisions under which it found that respondent continued to require treatment under MCL 330.1401(1). However, the underlying one-year continuing order selected all three provisions [MCL 330.1401(1); MCL 330.1401(1)(b); MCL 330.1401(1)(c)] as grounds for the probate court’s findings and order. Only one basis is necessary, but we conclude that there was clear and convincing evidence to support the trial court’s findings under all three provisions.” Ultimately, the testifying expert, a psychologist, and the two authorized reporters, another psychiatrist and a licensed master social worker, “all plainly provided evidence that respondent is a person suffering from mental illness and in need of mental health treatment.”