Bishop v. South Carolina Department of Mental Health

BURNETT, Justice:

This Court granted certiorari to review the Court of Appeals’ opinion in Bishop v. South Carolina Department of Mental Health, 323 S.C. 158, 473 S.E.2d 814 (Ct.App.1996). We affirm as modified.

FACTS

On March 1, 1990, Petitioner Brenda Bishop (grandmother) signed an affidavit which led.to the involuntary commitment of her daughter, Tammi Lee Hatley (mother), to Respondent South Carolina Department of Mental Health (Department) *84for mental illness. Specifically, grandmother alleged mother had made threats against Bobbi Hatley Robertson (victim), mother’s three-year-old daughter.…