In the Matter fo the Civil Commitment of J.B. v. Community Hospital North, 49A02-1706-MH-1295

J.B., a 33-year-old with a long-established diagnosis of schizophrenia and prior involuntary commitments, was admitted to Community Hospital North after refusing to leave his brother’s home and being observed misusing medication and heroin.
Hospital staff and Dr. Kanwaldeep Sidhu observed paranoia, delusional thinking, auditory hallucinations, agitation, threats toward staff, and two physical altercations with other patients shortly after admission.
Community North filed a Petition for Involuntary Commitment; the trial court found J.B. mentally ill, dangerous to others, and gravely disabled, and ordered regular commitment expected to exceed 90 days.
At the commitment hearing Dr. Sidhu testified to a very high and imminent risk that J.B. would harm others without months of medication; J.B.’s mother testified about longstanding inability to care for himself and prior violence and medication noncompliance.
J.B. disputed dangerousness and grave disability, arguing he wasn’t the initial aggressor in fights and that some evidence of past incidents was stale; he also testified he could eat and bathe and planned sheltered housing after release.
The trial court committed J.B.; he appealed, arguing insufficient evidence that he was dangerous or gravely disabled. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence sufficiently showed J.B. was "dangerous" under involuntary commitment standard	Community North: Dr. Sidhu and staff observed threats, fights, escalating agitation, and an imminent high risk to others due to untreated schizophrenia	J.B.: He was not the initial aggressor in fights; some events cited by mother were remote in time	Held: Sufficient evidence by clear and convincing standard; past and in-hospital threats, fights, agitation, and expert opinion established dangerousness
Whether evidence sufficiently showed J.B. was "gravely disabled"	Community North: J.B. was homeless, unemployable, had impaired judgment/forgetfulness, medication noncompliance, inability to maintain hygiene or food, and needed treatment to function	J.B.: He can eat and bathe in hospital, planned shelter placement and employment, and minimized severity of illness	Held: Alternatively sufficient; evidence supported inability to provide for basic needs and impaired functioning due to mental illness

Civil Commitment of T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (due process and evidentiary standards for involuntary commitment)
Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034 (Ind. Ct. App. 2016) (clear and convincing proof required for commitment)
In re Commitment of C.P., 10 N.E.3d 1023 (Ind. Ct. App. 2014) (distinguishing idiosyncratic behavior from serious mental illness supporting commitment)
Addington v. Texas, 441 U.S. 418 (1979) (clarifies intermediate clear-and-convincing standard)
C.J. v. Health & Hosp. Corp. of Marion Cnty., 842 N.E.2d 407 (Ind. Ct. App. 2006) (threats and violence can support finding of dangerousness)
B.M. v. Ind. Univ. Health, 24 N.E.3d 969 (Ind. Ct. App. 2015) (dangerousness must be linked to mental illness)
A.L. v. Wishard Health Servs., Midtown Cmty. Mental Health Ctr., 934 N.E.2d 755 (Ind. Ct. App. 2010) (inability to maintain housing/employment can support gravely disabled finding)