With no explanation, chose the best option from "A", "B", "C" or "D". did not testify about the specific actions that KE.W. had taken which caused Pugh to feel that K.E.W. was a threat, nor did Stone testify that any such specific actions caused Stone to believe that K.E.W. was likely to cause serious harm to others. Ortiz did not refer to the specific incident at all while stating her opinion. While KE.W’s beliefs and mental illness certainly give rise to the potential of harm to others, in order to support commitment, the threat of harm must be substantial and based on actual dangerous behavior manifested by some overt act or threats in the past. See J.M., 178 S.W.3d at 193; K.D.C., 78 S.W.3d at 547; Taylor, 671 S.W.2d at 538. “Potential” harm is not sufficient to deprive a person of his liberty. See J.M., 178 S.W.3d at 196; L.C.F., 96 S.W.3d at 657 (<HOLDING>); C.O., 65 S.W.3d at 181-82 (holding that

A: holding 50 potential members was not sufficient
B: holding even though experts are permitted to give an opinion they may not offer an opinion regarding the credibility of others
C: holding that an opinion of a potential danger to others is not sufficient to support a commitment under this standard
D: holding that potential civil commitment under a state statute was a collateral consequence of pleading guilty
C.