In the Matter of the Civil Commitment of M.L. v. Madison State Hospital (mem. dec.)
20A-MH-610
| Ind. Ct. App. | Sep 23, 2020Background
- Madison State Hospital filed a periodic report seeking continuation of M.L.’s regular involuntary commitment; the court initially continued without a hearing, then held a hearing after M.L. requested review.
- Treating psychiatrist Dr. Vincent Porter diagnosed M.L. with schizoaffective disorder, bipolar type, and described persistent, extensive delusions (e.g., cloning, government persecution, alien implants, grandiose beliefs).
- M.L. was reportedly nonresponsive to three antipsychotic medications and remained preoccupied with collecting and reviewing voluminous medical and legal records, staying up at night and foregoing group activities.
- Hospital staff observed escalating verbal and physical confrontations with peers and threats, necessitating transfers between units for safety.
- Dr. Porter testified M.L. had not met discharge criteria (six months of stable, nonaggressive behavior and willingness to participate in treatment) and concluded M.L. was gravely disabled and dangerous.
- The trial court continued M.L.’s regular commitment for one year; on appeal M.L. argued the Hospital failed to prove by clear and convincing evidence that he was dangerous or gravely disabled.
Issues
| Issue | Plaintiff's Argument (M.L.) | Defendant's Argument (Hospital) | Held |
|---|---|---|---|
| Whether clear and convincing evidence supported involuntary regular commitment (dangerousness or grave disability) | Insufficient evidence that M.L. is dangerous or gravely disabled | Dr. Porter’s testimony showed persistent delusions, medication resistance, disrupted functioning, and recent aggression supporting grave disability (and danger) | Affirmed: court found clear and convincing evidence M.L. is gravely disabled (no need to resolve dangerousness) |
Key Cases Cited
- T.K. v. Dep’t of Veterans Affairs, 27 N.E.3d 271 (Ind. 2015) (due process and standard for civil commitment reviews)
- In re Commitment of G.M., 743 N.E.2d 1148 (Ind. Ct. App. 2001) (clear and convincing evidence standard explained)
- T.D. v. Eskenazi Midtown Cmty. Mental Health Ctr., 40 N.E.3d 507 (Ind. Ct. App. 2015) (defines intermediate standard of proof)
- M.Z. v. Clarian Health Partners, 829 N.E.2d 634 (Ind. Ct. App. 2005) (only one of dangerousness or grave disability must be proved)
- Civil Commitment of W.S. v. Eskenazi Health, Midtown Cmty. Health, 23 N.E.3d 29 (Ind. Ct. App. 2014) (either prong of grave disability suffices on appeal)
- Golub v. Giles, 814 N.E.2d 1034 (Ind. Ct. App. 2004) (paranoia, delusions, threats, and refusal of treatment can support grave disability)
- In re Commitment of Roberts, 723 N.E.2d 474 (Ind. Ct. App. 2000) (civil commitment dual purpose: protect public and protect individual’s rights)