In the Matter of M.E., Alleged to Be Seriously Mentally Impaired, M.E., 16-1479

M.E., diagnosed with schizoaffective disorder, was involuntarily committed to Cherokee MHI after incidents and being delusional/hallucinating; she reported stopping meds as "harmful."
DAJ ordered inpatient commitment under Iowa Code §229.13 after an April 22 hearing; M.E. sought a 229.14A hearing on continued placement.
At the July 29 placement hearing, M.E. complained about medication side effects, requested outpatient release, and raised nonmedical concerns (religious services, phone access, contacting husband).
The State presented MHI physician assistant Mary Baughman, who testified M.E. refused effective oral meds and that observed "side effects" reflected therapeutic calming rather than adverse effects; M.E. had a short trial on Zyprexa and continued to show agitation and threatening episodes.
DAJ ordered continued placement; district court affirmed after de novo review. Appellate jurisdiction was contested but the court allowed a delayed appeal due to exceptional circumstances implicating due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate court has jurisdiction despite untimely appeal to wrong court	M.E.: exceptional circumstances (attorney error, delay, lack of reporter) justify delayed appeal	State: appeal should be dismissed as untimely; remedy lies in other statutory review mechanisms	Court granted delayed appeal on due process grounds and considered merits
Whether evidence was clear and convincing that M.E. lacked sufficient judgment to make treatment decisions	M.E.: refusal of meds was rational due to legitimate concerns about side effects; J.P. supports reasonable apprehension about side effects	State: refusal was irrational; staff observed that complaints were not credible and refusal prevented effective treatment	Court held substantial evidence supported finding M.E. lacked sufficient judgmental capacity and affirmed commitment

Addington v. Texas, 441 U.S. 418 (1979) (civil commitment requires due process; heightened standard of proof)
B.A.A. v. Chief Med. Officer, Univ. of Iowa Hosps. & Clinics, 421 N.W.2d 118 (Iowa 1988) (right to release when not seriously mentally impaired)
State v. Olsen, 794 N.W.2d 285 (Iowa 2011) (timeliness of appeals deprives appellate jurisdiction)
Swanson v. State, 406 N.W.2d 792 (Iowa 1987) (authority to grant delayed appeals when due process requires)
In re B.B., 826 N.W.2d 425 (Iowa 2013) (standard of review for sufficiency-of-evidence challenges under chapter 229)
In re J.P., 574 N.W.2d 340 (Iowa 1998) (concern about medication side effects can be reasonable and weigh against finding lack of judgment)
In re B.T.G., 784 N.W.2d 792 (Iowa Ct. App. 2010) (definition of inability to make rational treatment decisions under chapter 229)
Blanchard v. Brewer, 429 F.2d 89 (8th Cir. 1970) (due process considerations for delayed appeals)