In re R.T., 2019 Ohio 618

Appellant R.T. threatened Wal-Mart employees, was charged with criminal trespass and aggravated menacing, and found incompetent to stand trial; competency restoration failed.
Municipal court dismissed the criminal complaint as unrestorable; an affidavit of mental illness was filed and TVBH (Twin Valley) sought authorization to forcibly medicate R.T.
A magistrate ordered R.T. committed as a mentally ill person subject to hospitalization and authorized forced psychotropic medication; the trial court adopted that decision after hearing objections.
Drs. Iverson and Savageau testified R.T. suffers schizophrenia/delusional disorder, lacks insight, refuses medication, poses a risk to self/others, and would benefit from medication; both found no less-intrusive effective alternative.
Appellant appealed pro se arguing (in essence) the commitment and forced-medication orders were unsupported and improperly relied on past incidents; the court considered the appeal though R.T. had been discharged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of civil commitment under R.C. Chapter 5122	Commitment was improper/against manifest weight; relied on criminal history and prior incidents	Evidence (affidavit + expert testimony) met clear-and-convincing standard showing mental illness, gross impairment, and statutory danger	Commitment affirmed: competent, credible evidence supported findings under R.C. 5122.01(B) and Burton factors
Authorization of forced psychotropic medication	Forced medication was improper and possibly premised on prior incidents	Doctors testified R.T. lacked capacity to consent, benefits outweigh risks, and no less-intrusive effective treatment exists (Steele factors)	Forced-medication order supported by clear-and-convincing evidence per Steele; affirmed
Mootness of appeal of medication order	Appellant had been discharged and received medication, so relief is moot	Court recognized stigma and applied "capable of repetition yet evading review" exception; nonetheless found the record supports the order	Case not dismissed as moot under exception; merits adjudicated and judgment affirmed

In re Miller, 63 Ohio St.3d 99 (Ohio 1992) (importance of following statutory scheme to protect due-process rights in involuntary commitment)
Cross v. Ledford, 161 Ohio St. 469 (Ohio 1954) (definition of clear and convincing evidence)
State v. Scheibel, 55 Ohio St.3d 71 (Ohio 1990) (appellate review when clear-and-convincing proof is required)
In re Burton, 11 Ohio St.3d 147 (Ohio 1984) (totality-of-the-circumstances factors for civil commitment)
Steele v. Hamilton Cty. Community Mental Health Bd., 90 Ohio St.3d 176 (Ohio 2000) (three-part standard for court authorization of forced psychiatric treatment)
Witkowski v. Arditi, 123 Ohio App.3d 26 (7th Dist. 1997) (mootness principles and when a controversy lacks practical effect)