In the Matter of the Commitment of M.W. v. Madison State Hospital (mem. dec.), 71A03-1706-MH-1449

M.W., a 52-year-old with a long history of psychosis (schizoaffective/schizophrenia), has had repeated psychiatric commitments since 2009 and continuous hospitalization at Madison State Hospital since 2014.
Recurrent facts include severe self-care deficits, unsanitary/uninhabitable living conditions, threats to others/animals, violent and sexually inappropriate acts, and numerous prior readmissions after discharge.
Multiple hospitals and periodic reports documented refusal of medication in the community, outpatient treatment failures (including escape from a group home), and need for supervision and involuntary medication to prevent decompensation.
At the May 31, 2017 hearing, Madison psychiatrist Dr. Heaton testified that M.W. is gravely disabled if he does not stay on medication and that a locked facility was necessary to ensure adherence and safety.
M.W. testified that he would take medication only if compelled by court order but also stated he saw no reason to take meds — inconsistent with his long history of noncompliance.
The trial court found M.W. mentally ill and gravely disabled and ordered continued commitment to Madison State Hospital; M.W. appealed the sufficiency of the evidence supporting grave disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence clearly and convincingly proved M.W. was gravely disabled under IC 12-7-2-96	M.W. argued hospital failed to prove grave disability; pointed to his testimony that he would take meds if court-ordered	Hospital pointed to history of repeated decompensation off meds, prior commitments, documented inability to care for self, and Dr. Heaton’s testimony that without meds he is gravely disabled	Affirmed: clear and convincing evidence supported grave disability (unable to provide for basic needs and impaired functioning without meds)
Whether court impermissibly weighed evidence or credibility	M.W. urged appellate reweighing of his testimony and asserted less restrictive options	State relied on objective records, expert testimony, and M.W.’s history showing outpatient failures	Affirmed: appellate court defers to factfinder; M.W.’s inconsistent testimony and history insufficient to overturn finding

In re Commitment of Roberts, 723 N.E.2d 474 (Ind. Ct. App. 2000) (describing dual purposes of civil commitment and due process need for clear and convincing proof)
Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448 (Ind. Ct. App. 1991) (clear-and-convincing standard reduces chance of inappropriate commitments)
Bud Wolf Chevrolet, Inc. v. Robertson, 519 N.E.2d 135 (Ind. 1988) (standard for appellate review of sufficiency under clear-and-convincing evidence)
Civil Commitment of T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (framework for involuntary commitment and evidentiary standards)
Civil Commitment of W.S. v. Eskenazi Health, Midtown Cmty. Mental Health, 23 N.E.3d 29 (Ind. Ct. App. 2014) (statute is disjunctive; grave disability may be shown by inability to provide basic needs or by substantial impairment in judgment/behavior)
Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034 (Ind. Ct. App. 2016) (appellate courts will not reweigh evidence or assess witness credibility)