In the Matter of the Civil Commitment of T.D. v. Eskenazi Health Midtown Community Mental Health Center, 2015 Ind. App. LEXIS 526

T.D., a 51-year-old with bipolar disorder, had been on a regular civil commitment with Eskenazi Health (the Hospital); that commitment was terminated in September 2014 after she elected voluntary treatment.
After termination she moved from residential care to a shelter and then a hotel, became inconsistent with medications, and refused further voluntary treatment according to her treating psychiatrist, Dr. Michael DeMotte.
While staying in the hotel, T.D. flooded her room intending to set off the fire alarms so the fire department would assist her with preparing a presentation—an isolated, non-injurious incident that prompted emergency detention.
The Hospital sought a regular commitment under Ind. Code § 12-26-7-1; Dr. DeMotte testified that T.D. exhibited manic symptoms (grandiosity, distractibility, impulsivity), had impaired judgment off treatment, could not maintain housing without treatment, and recommended regular commitment transitioning to outpatient care.
The trial court found T.D. "gravely disabled" and ordered a regular commitment with medication and clinic attendance mandated; T.D. appealed, challenging sufficiency of the clear-and-convincing evidence.

Issue	Plaintiff's Argument (Hospital)	Defendant's Argument (T.D.)	Held
Whether evidence supported regular commitment under the "gravely disabled" definition	T.D. could not maintain shelter, refused treatment, hotel incident plus psychiatrist testimony showed impaired judgment and need for custody/care	Evidence was only an isolated incident, housing in a hotel is shelter, refusal to medicate alone insufficient, no proof she could not meet basic needs or was in danger	Reversed: evidence insufficient to show gravely disabled by clear and convincing standard

Addington v. Texas, 441 U.S. 418 (1979) (due process requires high proof standard for involuntary commitment; warns against commitment based on isolated conduct)
Civil Commitment of T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (clear-and-convincing proof required; refusal to medicate alone insufficient; isolated misconduct inadequate)
Commitment of G.M. v. Midtown Cmty. Health Ctr., 743 N.E.2d 1148 (Ind. Ct. App. 2001) (discusses Addington and proof standards for commitment)
Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448 (Ind. Ct. App. 1991) (warns against commitment based on idiosyncratic behavior)
Commitment of W.S. v. Eskenazi Health, Midtown Cmty. Health, 23 N.E.3d 29 (Ind. Ct. App. 2014) (disjunctive prongs of gravely disabled can independently support commitment)
Commitment of L.W. v. Midtown Cmty. Health Ctr., 823 N.E.2d 702 (Ind. Ct. App. 2005) (civil commitment implicates substantial liberty interests and due process)
K.F. v. St. Vincent Hosp. & Health Care Ctr., 909 N.E.2d 1063 (Ind. Ct. App. 2009) (reversed commitment for insufficient evidence)
Lazarus Dep’t Store v. Sutherlin, 544 N.E.2d 513 (Ind. Ct. App. 1989) (defines clear-and-convincing standard)