1980); In re Beverly, 342 So.2d 481, 486 (Fla. 1977); In re Albright, 836 P.2d 1, 6 (Kan.Ct.App. 1992); In re LaBelle, 728 P.2d 138, 143-46 (Wash. 1986). We signaled in In re L.R., 146 Vt. 17, 20-22, 497 A.2d 753, 755-57 (1985), that we would view the concept of dangerousness flexibly in accordance with the circumstances before us. In that case, we declined to adopt an overt act requirement, finding it was not a prerequisite to compliance with due process.
In sum, to demonstrate that T.H. was a person in need of treatment, the State was required to prove that T.H. had a mental illness and that he posed a danger to himself or others and this could be shown with evidence of threats or behavior. See In re L.R., 146 Vt. 17, 21, 497 A.2d 753, 756 (1985) (explaining that risk of harm to self or others can be shown by threats or acts). On appeal, T.H. argues that the court erred in finding that there was clear and convincing evidence that T.H. represented a danger to others.
This testimony provided sufficient support for the trial court's conclusions that E.T. would present a risk of future harm if she were discharged from the Hospital, and was therefore a "patient in need of further treatment" who required hospitalization under § 7621(b). See In re L.R., 146 Vt. 17, 19, 497 A.2d 753, 755 (1985) (this Court accepts as legitimate testimony from treating psychiatrists who make "predictions of future consequences"); see also 18 V.S.A. § 7622(a) ("A mental health professional testifying at hearings conducted under this part may, if appropriately qualified, give opinion testimony and . . . describe any information which he acquired in attending the patient."). II.
See Taylor, 618 P.2d at 1137. In re L.R., 146 Vt. 17, 21, 497 A.2d 753, 756 (1985) (emphasis added); see also In re Gatson, 3 Kan. App. 2d 265, 267-68, 593 P.2d 423, 426 (1979) (due process satisfied by finding of present dangerousness and mental impairment). We therefore hold that the dangerousness requirement of sections 27-10-107, -109 and -111 satisfies the demands of due process so long as the state proves by clear and convincing evidence that there is a reasonable basis to believe that the individual's mental illness results in a present danger to herself or others, or renders her gravely disabled. This standard is adequate to justify the massive curtailment of liberty inherent in involuntary commitment.