STATE OF SOUTH DAKOTA ) IN CIRCUIT COURT

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COUNTY OF CODINGTON ) THIRD JUDICIAL CIRCUIT
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In the matter of )
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) VERIFIED PETITION FOR
RENEE AMBER HOOVER, ) INVOLUNTARY COMMITMENT
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An alleged alcoholic and/or drug abuser )
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PHILLIP WAYNE KIRK, being duly sworn, on oath informs and petitions the court as follows:

1. Age and Competence:

I am eighteen (18) years of age or older and wholly competent.

2. Residence:
I reside at 420 8th St SE, Watertown, Codington County, South Dakota, and am a sibling
to the alleged alcoholic or drug abuser, Renee Amber Hoover.

3. Allegations of Alcohol or Drug Abuse:

I believe that Renee Amber Hoover is an alcoholic or drug abuser who habitually lacks
self-control as to the use of alcoholic beverages or drugs. She has threatened, attempted,
or inflicted physical harm on herself or another, and unless committed, is likely to inflict
harm on herself or another. She is incapacitated by the effects of alcohol or drugs.
Furthermore, the alleged alcoholic or drug abuser has refused to submit to a medical
examination or an alcohol/drug evaluation.

4. Basis for Belief:

The facts and circumstances which form the basis for my belief are as follows:

a. Background and Relationship:

I, Phillip Wayne Kirk, reside at the address listed above and am a lifelong resident
of Codington County, South Dakota. Renee Amber Hoover, my sister, also resides
in Watertown, SD. I submit this statement in support of my petition for her
involuntary commitment for medical treatment due to severe health issues directly
resulting from chronic alcohol abuse.
b. History of Addiction & Abuse
When Renee was in her twenties, she was a user of methamphetamine and other
narcotics. After relocating to South Dakota with her family, Renee has, as far as I
know, been clean from methamphetamine but continues to struggle with abusing
prescription medication and alcohol, oftentimes simultaneously. During the last
five years, Renee has been treated for various mental and behavioral health issues,
including alcoholism. She has also been admitted to in-patient treatment programs
to treat these and other underlying issues. On more than one occasion, Renee has
attempted to self harm by taking unknown amounts of medications both
prescribed and not prescribed.

c. Description of Concerns:
In recent months, Renee has displayed increasingly erratic and concerning
behavior, symptomatic of her advanced alcohol dependence. Despite her claims of
minimal alcohol consumption, medical tests have frequently shown high blood
alcohol levels. Notably, a recent incident involved her presenting at the
emergency room with symptoms of severe intoxication, where blood tests
confirmed a blood alcohol content indicative of impairment.

d. Medical Incidents and Health Status:

Renee has been diagnosed with alcoholic ketoacidosis, a serious and potentially
life-threatening condition, yet she has refused the necessary medical treatment.
On a recent visit to the emergency room, despite the medical staff's
recommendation for a minimum five-day hospital stay, Renee left the hospital
against medical advice after her request for Librium was denied.

e. Physical Appearance and Familial Relationships

Her physical appearance has deteriorated significantly, showing visible signs of
malnutrition and other health issues consistent with chronic alcohol abuse. This
has not only impacted her health severely but has also led to the loss of her
privileges to see her grandchildren, adding to the family's distress.

f. Previous Attempts to Address the Issue:

As a family, we have attempted multiple interventions to support and encourage
Renee towards recovery. Unfortunately, these efforts have been consistently
resisted or outright refused. Her denial of the severity of her situation and refusal
to seek help has left us with no other recourse but to seek involuntary
commitment as a means to ensure her safety and well-being.

g. Conclusion and Request:

Given Renee's current state and repeated refusal to acknowledge or treat her
condition, it is my assessment and that of our family that she is not capable of
making rational decisions regarding her health. We are deeply concerned that
without intervention and professional treatment, her condition will continue to
deteriorate, possibly resulting in fatal consequences.
THEREFORE, I request the Court set an early date for hearing on this petition and direct the
notice to be given; that upon hearing, Renee Amber Hoover, the alleged alcoholic and/or drug
abuser, be committed to the custody of Human Service Agency, or any other treatment program
or facility as the court sees fit, for treatment of alcoholism and/or drug abuse pursuant to SDCL
34-20A-70.

Dated this Third Day of May, 2024 at Codington County, South Dakota

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Phillip Wayne Kirk (Petitioner)