HORIZON HOSPITAL, APPELLANT,
v.
CHAD WILLIAMS, BY AND THROUGH HIS FATHER AND NEXT FRIEND, JON DANIEL WILLIAMS, APPELLEES
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The court held that the plain language of the statute requires the petition for involuntary placement to be executed, not filed, within the 72-hour period.
[1] A petition for involuntary placement must be executed by the facility administrator within the 72-hour examination period.
[2] A court may not disregard the plain language of a statute in favor of what it deems a more reasonable construction.
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Join FLexlaw to unlock all legal intelligenceA patient was involuntarily admitted to a hospital for psychological examination. The patient petitioned for a writ of habeas corpus, arguing release …
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CURRY, CHARLES B., Associate Judge.
Appellant, Horizon Hospital, challenges an order of release entered after the trial court granted appellee’s petition for a writ of habeas corpus. Appellant contends that the trial court incorrectly interpreted sections 394.463(2)(c) and (d), Florida Statutes (1991), which concern the procedures for involuntary psychological examination. We agree and reverse.
After being involuntarily admitted to Horizon Hospital for a psychological examination, Chad Williams, by and through his father and next friend, petitioned for a writ of habeas corpus arguing that he should be released because the hospital had failed to file a petition for involuntary placement within 72 hours of appellee’s entry into the facility. The trial court issued the writ and ordered appellee’s release. In the order of release the trial court ruled that pursuant to sections 394.463(2)(c) and (d), Florida Statutes (1991), the hospital was required to execute and file the petition for involuntary placement within the 72 hour period.
Section 394.463(2)(c) provides that a patient may be detained at a receiving facility for involuntary examination “no longer than 72 hours.” Section 394.-463(2)(d)4 provides that “within the examination period ... [a] petition for involuntary placement shall be executed by the facility administrator when treatment is deemed necessary....” The language of the statute is unambiguous and requires only that the petition for involuntary placement be executed within the 72 hour period. The trial court expressed concern that the filing could be unreasonably delayed if the statute were interpreted according to its plain language. However, no court is entitled to disregard the plain language of a statute in favor of what it deems to be a more reasonable construction. See More-trench American Corp. v. Taylor Woodrow Construction Corp., 565 So. 2d 861, 862 (Fla. 2d DCA 1990), approved sub nom., Taylor Woodrow Construction Corp. v. The Burke Company, 606 So. 2d 1154 (Fla.1992).
Reversed.
DANAHY, A.C.J., and FRANK, J., concur,
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Kraemer v. Gen. Motors Acceptance Corp. & Nationwide Ins. Co., 613 So. 2d 483 (Fla. 2d DCA 1992)…ords chosen by the legislature in their plain and ordinary meaning.... [T]he remédy for any dissatisfaction with the result[] ... lies with the legislature and not with [the] [c]ourt[s]. 606 So. 2d at 1155-56. See also Horizon Hospital v. Williams, 610 So. 2d 692 (Fla. 2d DCA 1992); Hillsborough County v. NCJ Investment Co., 605 So. 2d 1287 (Fla. 2d DCA 1992); Blount v. State, 581 So. 2d 604 (Fla. 2d DCA 1991); Dubrian v. Allstate Indemnity Co., 538 So. 2d 151, 152 (Fla. 2d DCA 1989); Nationwide Property & C…
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Potter v. Malee Potter (Fla. 1st DCA 2021)…Fla. 1st DCA 2010) (“Courts should exercise great caution before deviating from the plain text of a constitution, statute, or legislative document to purportedly avoid reaching what a court considers an ‘absurd result.’”); Horizon Hosp. v. Williams, 610 So. 2d 692, 693 (Fla. 2d DCA 1992) (“[N]o court is entitled to disregard the plain language of a statute in favor of what it deems to be a more reasonable construction.”). Here, the parties’ first marriage ended when an Alabama court entered a final judgment…
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Larry and Ellen Vickery v. City of Pensacola, 342 So. 3d 249 (Fla. 1st DCA 2022)…a particular statute.” State v. Rife, 789 So. 2d 288, 292 (Fla. 2001). “[N]o court is entitled to disregard the plain language of a statute in favor of what it deems to be a more reasonable construction.” Horizon Hosp. v. Williams ex rel. Williams, 610 So. 2d 692, 693 (Fla. 2d DCA 1992). III Contrary to the City’s contention, the words “documentation” and “danger” are unambiguous. They apply broadly, but their meanings are clear: “Documentation” refers to written evidence, and “danger” refers to risk of ha…
Authorities Cited
- Taylor Woodrow Constr. Corp. v. The Burke Co., 606 So. 2d 1154 (Fla. 1992)
- Moretrench Am. Corp. v. Taylor Woodrow Constr. Corp. & Am. Home Assurance Co., 565 So. 2d 861 (Fla. 2d DCA 1990)