In re the Civil Commitment of C.B. v. Eskenazi Health Midtown Community Mental Health (mem. dec.)
49A04-1606-MH-1256
Ind. Ct. App. Recl.May 4, 2017Background
- C.B., a 72-year-old retired teacher, exhibited persistent delusions (claiming FBI membership, presidential status, and political roles) and was admitted to Eskenazi Health in mid-May 2016 after multiple contacts with police and hospitals.
- Eskenazi filed for emergency detention and then sought involuntary commitment, alleging an unspecified psychotic disorder and that C.B. was gravely disabled.
- Dr. Thomas Beesley diagnosed a psychotic disorder, noted vitamin B12 deficiency possibly contributing to psychosis, prescribed Risperdal and IM B12, and testified C.B. lacked insight, housing stability, and capacity to follow outpatient care.
- At the hearing C.B. maintained delusional beliefs and offered inconsistent statements about housing; he conceded mental illness but contested the gravely disabled finding and treatment recommendations.
- The trial court entered a temporary commitment through August 24, 2016, finding C.B. gravely disabled under Ind. Code § 12-7-2-96; C.B. appealed.
Issues
| Issue | Appellant's Argument | Appellee's Argument | Held |
|---|---|---|---|
| Whether clear and convincing evidence supports involuntary commitment based on grave disability | C.B.: evidence insufficient to show grave disability; denial of illness/refusal to medicate alone cannot establish grave disability | Eskenazi: testimony and records show psychosis, B12-related medical risk, homelessness/unstable housing, inability to function or follow treatment | Affirmed — clear and convincing evidence supports finding of grave disability and temporary commitment |
| Whether the case is moot because commitment term ended | C.B.: commitment term renders appeal moot | Appellee: issue falls within public-interest exception and recurrent significance justifies decision on merits | Court applied public-interest exception and addressed merits |
Key Cases Cited
- In re J.B., 766 N.E.2d 795 (Ind. Ct. App. 2002) (mootness principles and public-interest exception)
- In re Lawrance, 579 N.E.2d 32 (Ind. 1991) (public-interest exception to mootness and recurring issues)
- In re Mental Commitment of M.P., 510 N.E.2d 645 (Ind. 1987) (statutory protections and individual dignity in commitment proceedings)
- Civil Commitment of T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (standard: commitment requires clear and convincing proof of mental illness and dangerousness or grave disability)