Snohomish County v. T.A.H.-L.

T.A.H.-L. (H.-L.) appeals her involuntary 90-day civil commitment under chapter 71.05 RCW. We hold that a person who is the subject of a petition for involuntary commitment under this chapter has a statutory right to the effective assistance of counsel. The standard by which we review the effectiveness of counsel is that set forth in Strickland v. Washington.1 In this case, the performance of counsel for H.-L. was neither deficient nor prejudicial. We affirm.

H.-L. has a significant history of mental illness and at least 12 prior hospitalizations for mental problems, including 3 at Western…