In the Matter of the Civil Commitment of: R.S. v. St. Vincent Hospital and Health Care Center, Inc., St. Vincent Stress Center (mem. dec.), 49A05-1701-MH-3

R.S., with a history of psychiatric treatment, was brought from North Carolina to Indianapolis after police reported she was roaming shelters and leaving provided housing.
Upon arrival she exhibited seizure-like convulsions, later assessed as psychiatric, and was admitted to St. Vincent Hospital.
At the hospital R.S. became paranoid (believing staff were poisoning her), refused most psychiatric medication, and claimed she could not speak; she intermittently took some general medical meds.
Dr. Shaun Wood diagnosed an unspecified psychosis (thought-disorder like schizophrenia), found R.S. unable to communicate effectively, and testified she could not meet basic needs or make safe decisions.
St. Vincent petitioned for involuntary temporary commitment; after a December 5, 2016 hearing the trial court found R.S. gravely disabled and ordered commitment through March 5, 2017.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported finding R.S. was "gravely disabled" for involuntary temporary commitment	R.S.: insufficient evidence; refusal to medicate and refusal to speak are idiosyncratic and, standing alone, do not show grave disability	St. Vincent: evidence that R.S. could not maintain shelter or meet essential needs, had delusions, and could not communicate needs — thus gravely disabled	Court affirmed: clear and convincing evidence R.S. was gravely disabled because she could not provide for essential needs and had impaired judgment/communication

Commitment of M.E. v. Dep’t of Veteran’s Affairs, 64 N.E.3d 855 (Ind. Ct. App. 2016) (standard for appellate review of civil-commitment sufficiency and clear-and-convincing proof)
Civil Commitment of T.K. v. Dep’t of Veteran’s Affairs, 27 N.E.3d 271 (Ind. 2015) (refusal to medicate or deny illness alone insufficient to prove grave disability)
Addington v. Texas, 441 U.S. 418 (1979) (commitment requires more than idiosyncratic behavior; higher proof standard)
Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448 (Ind. Ct. App. 1991) (no constitutional basis to confine mentally ill who can live safely in freedom)
A.L. v. Wishard Health Servs., Midtown Cmty. Mental Health Ctr., 934 N.E.2d 755 (Ind. Ct. App. 2010) (inability to maintain housing and delusions causing impaired judgment can support a finding of grave disability)
Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034 (Ind. Ct. App. 2016) (disjunctive statutory pathways to proving grave disability)