According to what I read he agreed to voluntary commitment, which is an option available to anyone who appears at involuntary commitment proceedings.  It does not sound like a contested hearing was even held; rather, he was offered the option of seeking treatment and agreed to it.  Pursuant to 37.2-809.B. of the Code of Virginia a petition for a temporary detention order is filed with the court and

a temporary detention order [is issued] if it appears from all evidence readily available, including any recommendation from a physician or clinical psychologist treating the person, that the person (i) has mental illness, (ii) presents an imminent danger to himself or others as a result of mental illness or is so seriously mentally ill as to be substantially unable to care for himself, (iii) is in need of hospitalization or treatment, and (iv) is unwilling to volunteer or incapable of volunteering for hospitalization or treatment.

The operative phrase is in italics.  There's a lot of confusing information out there, but if he agreed voluntarily to seek help then it's unlikely that there was any followup other than to make sure he made it to an initial meeting.  The hearing has to be held within 48 of the issuance of the detention order and the court scrambles to assemble the people necessary to conduct the hearing before the time expires.  The special justice, who is just an attorney specially appointed to conduct such hearings, is hauled into court, a local attorney willing to take these $25 cases (yes, you read that right.  The attorney's fee, unless it changed during the last session, is only $25) is called to come to court, a psychologist or psychiatrist on contract with the court is brought in, and the hearing is set.  It's a seat-of-the-pants type of proceeding in which the various parties are trying to sort out the facts in very short order and with minimal information available.  If the subject of the proceeding can walk and chew gum at the same time he is offered the option of voluntary commitment, which he will usually accept because it means he avoids the 72 hour hold which comes with an involuntary commitment.  So then he ends up going to the clinic or hospital voluntarily and talking to a whole new shrink.  Unless he's totally out of control or in the middle of a psychotic break he's going to be recommended for outpatient treatment. 

I've said it before - Virginia's mental health statutes are woefully inadequate and full of holes which allow seriously mentally ill individuals to evade any sort of supervision beyond the initial contact with the system.  If they can pull it together enough to deny that they're currently having any suicidal ideation and to deny that they want to hurt anybody they fall through the cracks and never come to the attention of the system again until the next crisis. 

which is that under the Virginia system it does not appear to me that Cho could be considered involuntarily committed because the statute requires that the involuntary committee be unwilling to voluntarily commit - that's why I said the fourth paragraph of the statute is the operative phrase.  In other words, he did not necessarily come within the meaning of the federal statute due to the incredibly narrow application of the Virginia statute.