In the Commitment of S.C. (mem. dec.)
49A04-1608-MH-1802
| Ind. Ct. App. | Jan 31, 2017Background
- Eskenazi Hospital filed an emergency detention application for S.C. on June 28, 2016; the trial court ordered temporary involuntary commitment through October 5, 2016.
- S.C. proceeded pro se, moved to belatedly appeal, and this Court allowed the late appeal but required an amended notice specifying which hearings should be transcribed.
- S.C. filed an amended notice but did not identify any hearing for transcription and did not provide a transcript.
- S.C.’s appellate brief asserted she was not mentally ill and that the police reports underlying the commitment were false, but her brief lacked headings, citations to the record, legal authority, and she did not file an Appellant’s Appendix including the commitment order or necessary documents.
- The Court found the record incomplete (relying only on the Clerk’s chronological case summary) and determined S.C. substantially violated appellate rules, impairing review; the Court dismissed the appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether S.C. should be released from involuntary commitment | S.C.: commitment was improper because she is not mentally ill and police reports were false | Eskenazi: appeal procedurally defective; record and brief insufficient for review | Waived/dismissed for substantial appellate rule violations and insufficient record |
| Whether appellate court can review merits absent transcript/appendix | S.C.: implicitly urges merits review despite missing materials | Eskenazi: lack of transcript/appendix prevents appellate review | Court will not review merits; appellant’s noncompliance waives issues |
| Whether alleged errors are moot due to commitment expiration | S.C.: seeks relief from commitment | Eskenazi: chronological summary suggests commitment expired | Court noted possible mootness based on expiration and dismissed |
| Whether pro se status excuses procedural noncompliance | S.C.: proceeded pro se without counsel | Eskenazi: pro se litigant held to same rules as counsel | Pro se status does not excuse noncompliance; errors waived |
Key Cases Cited
- In re Garrard, 985 N.E.2d 1097 (Ind. Ct. App. 2013) (pro se appellants are held to the same appellate rules; court will deem errors waived where noncompliance substantially impedes review)
- Ramsey v. Review Bd. of Ind. Dep’t of Workforce Dev., 789 N.E.2d 486 (Ind. Ct. App. 2003) (substantial noncompliance with appellate rules may result in waiver)
- Jackson v. Ind. Adult Protective Services, 52 N.E.3d 821 (Ind. Ct. App. 2016) (mental health commitment is a significant liberty restraint; appellate review requires an adequate record)
- Civil Commitment of W.S. v. Eskenazi Health, Midtown Cmty. Mental Health Ctr., 23 N.E.3d 29 (Ind. Ct. App. 2014) (appellate court will not reweigh evidence or assess witness credibility)
- Commitment of J.B., 766 N.E.2d 795 (Ind. Ct. App. 2002) (case is moot where court cannot render effective relief and is dismissed)