In the Matter of the Civil Commitment of S.T. v. Madison State Hospital (mem. dec.)
49A02-1610-MH-2401
| Ind. Ct. App. | Aug 3, 2017Background
- S.T., with an IQ of 57, was found incompetent to stand trial on child-molesting charges and was civilly committed in 2009; his commitment was renewed annually and he was transferred to Madison State Hospital in 2011.
- Hospital records and staff reported S.T. admitted multiple episodes of child molestation, viewing child pornography, and ongoing sexual attraction to prepubescent males.
- Hospital clinicians detailed repeated impulsive, boundary-violating sexual behavior toward peers in the hospital and placement on 15-minute nighttime checks to prevent attempts to enter others’ rooms.
- S.T. has a history of minimal or sporadic participation in sex-offender treatment and has been prescribed medication to reduce sexual drive, with only limited benefit.
- In 2016 S.T. moved for a review hearing and dismissal of his regular commitment; the trial court found S.T. mentally ill and dangerous to others and continued the commitment.
Issues
| Issue | Plaintiff's Argument (Madison State Hospital) | Defendant's Argument (S.T.) | Held |
|---|---|---|---|
| Whether hospital proved by clear and convincing evidence that S.T. is "dangerous to others" under the civil-commitment statute | Evidence of pedophilic disorder, admissions of past offenses, ongoing urges, repeated boundary-violating sexual conduct in hospital, poor treatment engagement, and risk assessments show substantial risk of harm | Challenges sufficiency: contests basis for restrictive measures, disputes risk-assessment methodology, argues admissions are unreliable and evidence was insufficient to establish dangerousness | Court affirmed: evidence satisfied clear and convincing standard; commitment continued |
Key Cases Cited
- Civil Commitment of T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (sets due-process and clear-and-convincing-evidence standard for involuntary commitment)
- In re Commitment of Roberts, 723 N.E.2d 474 (Ind. Ct. App. 2000) (discusses dual purpose of commitment proceedings—public protection and individual rights)
- Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448 (Ind. Ct. App. 1991) (discusses clear-and-convincing proof requirement in commitment cases)
- Bud Wolf Chevrolet, Inc. v. Robertson, 519 N.E.2d 135 (Ind. 1988) (articulates appellate standard for reviewing findings under clear-and-convincing evidence)
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (establishes that civil-commitment facts must be proved by clear and convincing evidence)