In Re the Involuntary Commitment of A.M., 2011 Ind. App. LEXIS 1810

A.M. appeals an order involuntarily committing her to a mental health facility, challenging the sufficiency of the evidence.
On September 23, 2010, A.M. caused a disturbance at a restaurant and was detained on an emergency basis at Deaconess Hospital.
Dr. James Given evaluated A.M. and diagnosed bipolar disorder with grave disability.
An emergency detention hearing occurred on October 1, 2010, and a temporary commitment was approved the same day.
Dr. Given filed a regular commitment request on December 6, 2010; at the December 22, 2010 hearing, he testified A.M. remained bipolar and gravely disabled, with delusions, poor insight, medication noncompliance, and agitation.
The trial court found A.M. mentally ill and gravely disabled and ordered regular involuntary commitment; A.M. timely appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record proves gravely disabled	A.M. argues evidence is insufficient	State contends substantial evidence shows gravely disabled	Yes; gravely disabled proven by substantial impairment and poor insight

J.S. v. Center for Behavioral Health, 846 N.E.2d 1106 (Ind. Ct. App. 2006) (grave disability evidence when patient off meds supporting commitment)
Bradbury, 845 N.E.2d 1063 (Ind. Ct. App. 2006) (delusions, agitation, and noncompliance as basis for grave disability)
Commitment of S.T., 930 N.E.2d 684 (Ind. Ct. App. 2010) (standard: review evidence in favor of trial court and avoid reweighing)
C.J. v. Health and Hosp. Corp. of Marion County, 842 N.E.2d 407 (Ind. Ct. App. 2006) (due process protections in civil commitment)