Knotts v. Psychiatric Security Review Board

Decisions of the Psychiatric Security Review Board must be supported by "substantial reasoning" in order to be affirmed by the Court of Appeals. Thus, if the board's reasoning cannot be ascertained or is faulty, the order must be reversed and remanded.

Kevin Knotts filed for conditional release from the Oregon State Hospital 14 months after being sent to the facility by the trial court. The Psychiatric Security Review Board (PSRB) denied the conditional release request because it felt "necessary elements" were missing and because they would have "little control" over petitioner if released to live in California. PSRB gave no explanation of what elements were missing or what control they would be lacking. The Court of Appeals reversed the board’s decision because it lacked "substantial reasoning." The Court held that an order is not supported by "substantial reasoning," if "the board's reasoning cannot be ascertained or is faulty." Since in this case the PSRB gave no reasoning or explanations for holding that Mr. Knotts conditional release was missing necessary elements, the order denying conditional release was not supported by substantial reasoning. Reversed and remanded.