In the Matter of the Commitment of J.M., J.M. v. Northeastern Center, Inc.
2016 Ind. App. LEXIS 394
| Ind. Ct. App. | 2016Background
- Northeastern Center filed a petition on August 10, 2015 seeking J.M.’s involuntary mental-health commitment for up to 90 days; fact-finding hearings occurred August 13 and August 20.
- Dr. Lynnea Carder testified J.M. was diagnosed with schizoaffective disorder, experienced delusions/hallucinations (believing she was an alien, not recognizing her daughter), and had made threats to family who feared her.
- Since admission, J.M. was described as religiously preoccupied, paranoid, explosive, belligerent, threatening staff, and on multiple occasions was restrained and secluded.
- J.M. was refusing oral medication; staff administered daily injectable antipsychotics, which partially controlled behavior but raised medical concerns for long-term use.
- The trial court found J.M. mentally ill, dangerous, and gravely disabled and ordered commitment not to exceed 90 days; J.M. appealed.
- Northeastern noted the 90-day commitment expired, rendering the appeal moot, but the appellate court exercised the public‑interest exception and addressed the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for involuntary commitment (dangerousness) | J.M.: evidence insufficient because witnesses did not describe actions leading to restraints or specific violent acts or threats at Northeastern | Northeastern: Dr. Carder’s testimony about prior threats to family, current belligerence, restraints/seclusions, paranoia, and refusal of medication showed substantial risk of harm | Court: Evidence was sufficient; reasonable fact‑finder could find J.M. dangerous and affirm commitment |
Key Cases Cited
- In re J.B., 766 N.E.2d 795 (Ind. Ct. App. 2002) (mootness and dismissal when court cannot grant effective relief)
- In re Lawrance, 579 N.E.2d 32 (Ind. 1991) (public‑interest exception to mootness and factors for addressing recurring issues)
- Ind. High Sch. Athletic Ass’n, Inc. v. Durham, 748 N.E.2d 404 (Ind. Ct. App. 2001) (public‑interest exception typically involves recurring issues)
- In re Mental Commitment of M.P., 510 N.E.2d 645 (Ind. 1987) (right to refuse treatment underscores individual dignity in commitment proceedings)
- In re Commitment of G.M., 743 N.E.2d 1148 (Ind. Ct. App. 2001) (standard for reviewing sufficiency of evidence in commitment cases)