In the Matter of M.F., Alleged to Be Seriously Mentally Impaired, M.F., 17-0031

M.F., with a long history of mental-health issues (including two suicide attempts and prior incarceration for threatening the federal government), was released from federal prison in January 2016.
After release he began using drugs, made threats to bank employees, sent conspiracy mail, and had escalating conflicts with family members.
On December 1, 2016, M.F.’s father sought involuntary hospitalization under Iowa Code chapter 229; a judicial hospitalization referee ordered commitment.
At a district-court hearing, the court took judicial notice of a physician’s report and admitted a second physician’s updated report; both doctors opined M.F. was a danger to himself or others.
District court found by clear and convincing evidence that M.F. is seriously mentally impaired: he lacks insight/judgment, would benefit from treatment, and is likely to physically injure himself or others or inflict serious emotional injury on family if untreated.
The court relied on a record of past threats, a federal conviction, recent physical altercations with his father (including lunging and spitting at the courthouse), and physicians’ opinions; M.F. appealed only the dangerousness finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved dangerousness for involuntary commitment under Iowa Code ch. 229	State: M.F. has recent overt acts, escalating threats, and physicians’ opinions predicting future danger, meeting the dangerousness criterion	M.F.: No recent overt acts or threats sufficient to prove likely future danger; past incidents are remote or nonviolent and father’s testimony undermines danger claim	Affirmed — substantial evidence supports dangerousness by clear and convincing evidence
Whether predictive judgment may rely on past manifestations	State: Past threats and behavior can ground a predictive finding of future danger	M.F.: Past conduct is too remote or nonviolent to support prediction	Affirmed — court applied predictive standard based on recent overt acts and escalation

In re B.B., 826 N.W.2d 425 (Iowa 2013) (standard of proof in involuntary commitment is clear and convincing evidence)
In re J.P., 574 N.W.2d 340 (Iowa 1998) (definition of clear and convincing evidence)
In re Oseing, 296 N.W.2d 797 (Iowa 1980) (elements of "seriously mentally impaired" include mental illness, lack of judgment, and dangerousness)
In re Mohr, 383 N.W.2d 539 (Iowa 1986) (dangerousness requires predictive judgment grounded in prior manifestations)
In re Foster, 426 N.W.2d 374 (Iowa 1988) ("overt act" denotes past aggressive behavior or threats manifesting probable dangerous acts)