State v. L.O.W. (In re L.O.W.)

*377Appellant seeks reversal of an order of civil commitment. On appeal, citing ORS 426.232(2),1 she contends that the trial court was required to dismiss the commitment case because appellant was involuntarily hospitalized for more than five days without a hearing. We agree and reverse.

The facts are procedural and not in dispute. On July 20, 2016, appellant was brought to Salem Hospital and was held there against her will under ORS 426.232, which allows "physician hold" at a hospital. Subsection (2) of that statute requires that she had to be released within five judicial days, or by July 27.…