State v. Salo

Appellant challenges an order finding him to be mentally ill and committing him to the Mental Health Division. At the hearing, the medical examiners agreed that appellant suffers from a mental disorder, but they did not agree as to whether he was a danger to himself or others within the meaning of ORS 426.005(2).1 Because the record is substantially incomplete, we are unable to perform a meaningful de novo review. Accordingly, we reverse.

Appellant was incarcerated in the county jail for more than three months before the commitment hearing was held. The hearing was tape-recorded, apparently…