that K.E.W. was disheveled and was wearing the same socks for weeks as proof of a diminished ability to clothe himself properly. But these facts were not cited as support by either Dr. Stone or Dr. Ortiz, neither of which spoke to the question of KE.W’s ability to function independently or to provide for his basic needs. “[P]oor grooming is insufficient ‘to justify depriving an individual of her liberty,’ ” and poor hygiene, while demonstrative of mental illness, does not, in itself “rise to the level of an overt act or pattern of behavior that confirms a substantial deterioration of a person’s ability to function independently to provide for her basic needs.” See Armstrong v. State, 190 S.W.3d 246, 252 (Tex.App.-Houston [1st Dist.] 2006, no pet.), citing to J.M., 178 S.W.3d at 195 (<HOLDING>). Section 574.034(a)(2)(C)(ii) requires a
recognizing a constitutional right of privacy in mental health records holding that patients refusal to bathe and brush her teeth did not rise to level of sufficient act or pattern of behavior to support court ordered mental health services holding the trial court violated the separation of powers doctrine when it ordered the office of the state attorney to pay for the costs of mental health experts evaluating the defendant holding that trial counsel did not act unreasonably in failing to raise the issue of the defendants mental health at trial recognizing counsels ability to waive statutory right to a mental health hearing