In the Matter of the Civil Commitment of V.H. v. St. Vincent Hospital & Health Care Center, Inc., d/b/a St. Vincent Stress Center (mem. dec.), 49A05-1701-MH-152

V.H., with a long history of major depression and borderline personality disorder, made multiple suicide attempts (at least eight), most often by overdosing on over‑the‑counter acetaminophen (Tylenol).
On December 23, 2016, V.H. was treated at St. Vincent for a potentially fatal Tylenol overdose and was given N‑acetylcysteine to prevent liver failure.
St. Vincent filed for emergency detention and then sought involuntary commitment; after a contested hearing the trial court ordered regular commitment.
As a condition of outpatient status, the court prohibited V.H. from using alcohol or drugs except those prescribed by a physician.
V.H. appealed, arguing the alcohol prohibition bore no reasonable relationship to her treatment because her past attempts involved Tylenol, not alcohol.

Issue	V.H.'s Argument	St. Vincent's Argument	Held
Whether a condition forbidding alcohol/drug use (except prescribed) for an outpatient commitment is supported by the record and reasonably related to treatment	The alcohol ban is unrelated to her treatment because her suicide attempts involved Tylenol, not alcohol	V.H. has a documented pattern of substance misuse (accessible substances used for suicide) and prohibiting nonprescribed substances protects her and the public	Affirmed: the prohibition is supported by evidence of repeated overdoses on readily available substances and is reasonably related to treatment; court declined to require parsing permitted substances

Commitment of M.M. v. Clarian Health Partners, 826 N.E.2d 90 (Ind. Ct. App. 2005) (struck alcohol/drug prohibition where record lacked any evidence of substance use)
Golub v. Giles, 814 N.E.2d 1034 (Ind. Ct. App. 2004) (similar rejection of a post‑commitment substance prohibition when alcohol/drug use was never shown at hearing)