In the Matter of the Civil Commitment of W.S. v. Eskenazi Health, Midtown Community Mental Health
23 N.E.3d 29
Ind. Ct. App.2014Background
- W.S., a 43-year-old diagnosed with paranoid schizophrenia, has been under a regular involuntary commitment to Midtown (Eskenazi Health) since March 2009 and receives monthly Haldol Decanoate injections.
- He lives independently but must attend Midtown appointments and receive court-ordered injections; he lacks insight and says he would not voluntarily take injections.
- Dr. Jeffrey Kellams and nurse Christopher Miller testified W.S. stabilizes on medication, would deteriorate without it, and likely would stop attending treatment if not committed.
- The trial court, after a March 25, 2014 review hearing, found W.S. mentally ill and gravely disabled and continued his regular commitment, including a condition that he take prescribed medication; the order set a one-year review date.
- W.S. appealed, arguing the evidence was insufficient—particularly regarding forced medication—while Midtown did not file a responsive brief on that issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence supports finding W.S. gravely disabled | W.S.: insufficient evidence that he is gravely disabled | Midtown: evidence of long history, lack of insight, deterioration without medication supports grave disability | Court: affirmed — clear and convincing evidence supports gravely disabled finding |
| Whether court-ordered forced medication is supported by M.P. factors | W.S.: no proof injections provide substantial therapeutic benefit (not just behavior control); no record of considering less restrictive alternatives; indefinite administration | Midtown: (no brief on appeal) trial testimony asserted injections necessary and beneficial | Court: remanded — record lacks specific evidence on substantial therapeutic benefit and rejection of alternatives; further hearing required |
| Whether forced medication order is indefinite | W.S.: order impermissibly indefinite | Midtown: (implicitly) order necessary for treatment continuity | Court: not indefinite — one-year review provision satisfies M.P. time-limit requirement |
| Appropriate remedy when commitment supported but medication order deficient | W.S.: seek reversal/termination of medication order | Midtown: (no response) | Court: affirm commitment; remand for additional hearing solely on medication issues so court can apply M.P. criteria |
Key Cases Cited
- M.L. v. Meridian Servs., Inc., 956 N.E.2d 752 (Ind. Ct. App. 2011) (standard for civil commitment and appellate review)
- J.S. v. Ctr. for Behavioral Health, 846 N.E.2d 1106 (Ind. Ct. App. 2006) (forced-medication analysis where patient would be gravely disabled if off antipsychotics)
- In re Mental Commitment of M.P., 510 N.E.2d 645 (Ind. 1987) (requirements to override right to refuse medication and limits on forced-medication orders)
- In re Commitment of G.M., 938 N.E.2d 302 (Ind. Ct. App. 2010) (remand for further proceedings rather than termination when some commitment elements are deficient)
- In re Commitment of J.B., 766 N.E.2d 795 (Ind. Ct. App. 2002) (insufficient evidence to support forced-medication order during temporary commitment)