In the Matter of the Commitment of P.B. v. Evansville State Hospital
90 N.E.3d 1199
| Ind. Ct. App. | 2017Background
- P.B. diagnosed with schizoaffective disorder and PTSD and has a history of involuntary commitments in Indiana (since 2011) and hospitalizations in other states.
- Prior to December 2016–February 2017 proceedings she exhibited paranoid delusions (believing neighbors/family were breaking in and harming her), made frequent nuisance police calls, and was noncompliant with outpatient treatment and antipsychotic medication.
- Transferred to Evansville State Hospital in February 2017; the hospital sought continuation of a regular involuntary commitment (beyond 90 days) on the ground of grave disability.
- Dr. Vatel (hospital psychiatrist) testified P.B. was not suicidal or physically dangerous but had severe delusions, mood lability, difficulty cooperating with treatment, and interpersonal dysfunction; he opined she might deteriorate outside the hospital.
- The trial court continued P.B.’s regular involuntary commitment. On appeal the court evaluated whether the hospital proved grave disability by clear and convincing evidence—i.e., present inability to provide food, clothing, shelter, or an obvious deterioration of judgment/behavior causing inability to function independently.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence supported continuation of a regular involuntary commitment for grave disability | P.B.: hospital failed to present clear and convincing evidence that she currently cannot provide for food, clothing, shelter, or otherwise function independently | Hospital: P.B.'s persistent delusions, medication refusal, mood lability, hostility, and inability to get along show present grave disability and risk of deterioration if released | Reversed — evidence insufficient: no proof P.B. currently cannot provide essentials or is presently unable to function independently; speculation about future deterioration is insufficient |
Key Cases Cited
- Civil Commitment of T.K. v. Dep’t of Veteran Affairs, 27 N.E.3d 271 (Ind. 2015) (clarifies standard of review and requires present, clear-and-convincing proof of dangerousness or grave disability; refusal of meds alone insufficient)
- T.D. v. Eskenazi Health Midtown Cmty. Health Ctr., 40 N.E.3d 507 (Ind. Ct. App. 2015) (reversed commitment where evidence failed to show inability to maintain shelter/essentials)
- Commitment of M.E. v. Dep’t of Veterans Affairs, 64 N.E.3d 855 (Ind. Ct. App. 2016) (reversed where paranoia and noncompliance did not show present inability to provide essentials)
- Commitment of B.J. v. Eskenazi Hospital, 67 N.E.3d 1034 (Ind. Ct. App. 2016) (holds hypothetical future deterioration cannot replace present-showing of grave disability)
- In re Involuntary Commitment of A.M., 959 N.E.2d 832 (Ind. Ct. App. 2011) (earlier decision relied on by hospital but given little weight here because its standard of review was later disapproved)