Commitment of T.A. v. Wishard Health Service, Midtown Community Mental Health Center
2011 Ind. App. LEXIS 1147
| Ind. Ct. App. | 2011Background
- T.A. was admitted to Wishard after she publicly removed her clothes in downtown Indianapolis.
- Wishard sought emergency detention and a temporary commitment on the basis of mania and gravely disabled status.
- Dr. DeMotte diagnosed bipolar disorder with manic episode and supported a temporary commitment.
- The trial court held T.A. gravely disabled and ordered temporary commitment.
- T.A. contested the gravely disabled finding, arguing insufficient evidence.
- On appeal, mootness was acknowledged but the court proceeded to address the merits based on public interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether clear and convincing evidence supports gravely disabled finding | Wishard: gravely disabled based on impaired judgment and ability to meet basic needs | T.A.: insufficient evidence of gravely disabled | Yes; evidence supports gravely disabled finding |
Key Cases Cited
- In re Commitment of Steinberg, 821 N.E.2d 385 (Ind.Ct.App.2004) (moot cases may be decided on merits in public interest)
- In re Commitment of K.F., 909 N.E.2d 1063 (Ind.Ct.App.2009) (review of gravely disabled standard; deference to trial court on credibility)
- In re Commitment of A.L., 934 N.E.2d 755 (Ind.Ct.App.2010) (gravely disabled; moved from place to place; lack of independent functioning supports commitment)