The following excerpt is from Rawson v. Recovery Innovations, Inc., 975 F.3d 742 (9th Cir. 2020):
9 See also Beltran-Serrano v. City of Tacoma , 193 Wash.2d 537, 442 P.3d 608, 614 n.9 (2019) (referring to the "detention of a person suffering from mental illness" as a "law enforcement related activit[y]"); Developments in the Law, Civil Commitment of the Mentally Ill , 87 Harv. L. Rev. 1190, 120712, 122223 (1974) (describing the origins of the parens patriae and police powers relating to the mentally ill).
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