In the Matter of the Civil Commitment of C.P., C.P. v. Community Hospital North/Gallahue Mental Health
10 N.E.3d 1023
| Ind. Ct. App. | 2014Background
- C.P. self-presented to Community Hospital North ER on Aug. 18, 2013 claiming repeated spider bites and related "venom" effects; medical staff found no bites and referred her to psychiatry.
- This was her fourth ER visit in 31 days for the same delusional complaint; police and doctors previously found no evidence of spiders or bites.
- A psychiatrist evaluated C.P. daily for five days, diagnosed Psychosis Not Otherwise Specified, and concluded she lacked insight, refused medications, and could not meet basic needs (unable to live or cook in her home, lost her job).
- The psychiatrist testified C.P. was gravely disabled and posed a risk of engaging in dangerous behavior (e.g., burning the house, living in her car, potential self-harm) tied to her delusions.
- The trial court ordered a 90-day involuntary commitment to stabilize her on antipsychotics; the psychiatrist expected possible discharge to outpatient care in 10–14 days.
- Although the commitment had ended (mootness), the court of appeals addressed the appeal on the merits due to recurring public-interest issues in involuntary commitment cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was clear and convincing that C.P. was gravely disabled | C.P.: No underlying facts show substantial impairment of judgment causing inability to function independently | Hospital: Psychiatrist’s testimony showed inability to provide food, shelter, employment loss, medication noncompliance, and impaired judgment from delusions | Court: Affirmed — psychiatrist’s testimony provided clear and convincing proof of grave disability |
| Whether appeal should be dismissed as moot | C.P.: Commitment ended, so appeal is moot | Hospital: Case raises recurring public-interest questions warranting review on the merits | Court: Addressed merits despite mootness because issue is likely to recur and implicates significant public interest |
Key Cases Cited
- Commitment of S.T. v. Community Hosp. North, 930 N.E.2d 684 (Ind. Ct. App. 2010) (involuntary commitment raises substantial due process concerns; public-interest exception to mootness)
- G.Q. v. Branam, 917 N.E.2d 703 (Ind. Ct. App. 2009) (standard of review for sufficiency in civil commitment cases)
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (heightened evidentiary standard and need for proof beyond idiosyncratic behavior in civil commitment)
- In re Involuntary Commitment of A.M., 959 N.E.2d 832 (Ind. Ct. App. 2011) (grave disability may be found based on medication noncompliance, lack of insight, and functional deterioration)