In the Matter of B.L., Alleged to Be Seriously Mentally Impaired, B.L., 16-0951

B.L. was subject to an involuntary hospitalization order under Iowa Code chapter 229 after several weeks of delusional beliefs (e.g., claiming ownership of a company, having twenty children, believing neighbors stole dirt, and claiming to be a federal agent).
The petition was initiated by B.L.’s father based on concern about B.L.’s behavior and delusions.
Treating physician testified B.L. was delusional but never aggressive, capable of self-care, polite when refusing medication, and unlikely to harm himself; the doctor acknowledged a hypothetical risk of an altercation if confronted but admitted no threats or violence had occurred.
The father testified B.L. made statements about firing people but did not threaten physical harm and was calm during those statements.
The district court ordered involuntary commitment; B.L. appealed, arguing the State failed to prove he was "seriously mentally impaired" under Iowa law by clear and convincing evidence, specifically lacking proof of recent overt dangerousness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence met the clear-and-convincing standard that B.L. is "seriously mentally impaired" under Iowa Code § 229.1(20)	B.L.: his delusions did not show lack of judgment plus the required recent overt act demonstrating dangerousness	State: delusions, behavior, and physician concerns supported commitment as B.L. posed a risk if at liberty	Reversed: evidence did not meet clear-and-convincing standard because no recent overt act or threats showing probable danger
Whether constitutional due-process/dangerousness requirement (recent overt act) was satisfied	B.L.: no recent overt act, threats, or violence; abnormal behavior alone insufficient	State: argued B.L.’s delusions and possible future risk justified commitment	Held for B.L.: constitutional standard requires recent overt act; absent threats/violence, commitment improper

In re J.P., 574 N.W.2d 340 (Iowa 1998) (civil commitment is a special action; findings reviewed for correction of errors at law)
In re Oseing, 296 N.W.2d 797 (Iowa 1980) (clear-and-convincing standard required for commitment)
In re L.G., 532 N.W.2d 478 (Iowa Ct. App. 1995) (definition of clear and convincing evidence)
In re B.B., 826 N.W.2d 425 (Iowa 2013) (comparative burden explanation: clear-and-convincing between preponderance and beyond a reasonable doubt)
In re Foster, 426 N.W.2d 374 (Iowa 1988) (defining the elements of serious mental impairment and meaning of "likely")
O'Connor v. Donaldson, 422 U.S. 563 (1975) (constitutional requirement that dangerousness be shown before involuntary confinement)
In re Mohr, 383 N.W.2d 539 (Iowa 1986) (requiring proof of a recent overt act, attempt, or threat to establish dangerousness for commitment)