In the Matter of T.M., Alleged to Be Seriously Mentally Impaired, T.M., 16-0332

T.M. was the subject of an involuntary civil commitment proceeding under Iowa Code chapter 229.
The district court found T.M. to be “seriously mentally impaired” and ordered commitment.
The record relied on medical reports and testimony from T.M.’s treating physician.
Physician testimony established diagnoses including schizophrenia and psychosis and concluded T.M. lacked sufficient judgment to make treatment decisions.
T.M. had recently attempted suicide by hanging with a bedsheet, which prompted the commitment referral and supported dangerousness to self.
T.M. appealed, challenging the sufficiency of the evidence supporting the “seriously mentally impaired” finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence met the clear-and-convincing standard for "seriously mentally impaired" under Iowa Code ch. 229	T.M. argued the evidence was insufficient to support the finding.	State argued medical reports and treating physician testimony established mental illness, lack of judgment, and recent dangerous act.	Affirmed: substantial, clear-and-convincing evidence supported commitment.

In re J.P., 574 N.W.2d 340 (Iowa 1998) (standard of review for involuntary commitment proceedings)
In re Oseing, 296 N.W.2d 797 (Iowa 1980) (clear-and-convincing evidence 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 discussion of proof standards)
In re Foster, 426 N.W.2d 374 (Iowa 1988) (substantial-evidence standard for factual findings)