K.J. v. State of Indiana (mem. dec.)
18A02-1607-MH-1610
| Ind. Ct. App. | Jan 18, 2017Background
- K.J., diagnosed with schizoaffective disorder, was involuntarily committed to Richmond State Hospital (RSH) in Nov. 2013 after emergency detention and a finding she was gravely disabled.
- Annual reviews in 2014 and 2015 led to transfers and continued commitments; she was placed at Meridian Health Services (MHS) for less restrictive care but had repeated ER admissions and hospitalizations in 2015–2016.
- MHS filed a petition for expedited review and requested more restrictive placement in June 2016; a hearing was held June 10, 2016.
- Testimony from MHS clinicians (a behavioral clinician and treating psychiatrist) described deterioration: repeated hospitalizations, medication noncompliance, substance use, impulsive/harmful behavior, hostility, and suicidal risk.
- Trial court found K.J. mentally ill, gravely disabled, and dangerous to herself, ordered continuation of her regular commitment and placement at RSH.
- K.J. appealed, arguing (1) insufficient evidence to support continuation of regular commitment (specifically grave disability), and (2) Indiana Code ch.12-26-15 is unconstitutional because it does not require an automatic hearing for annual reviews.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to continue regular commitment (gravely disabled) | K.J.: evidence insufficient to show grave disability (unable to function independently or provide for basic needs) | State: clinicians’ testimony (deterioration, repeated hospitalizations, suicidality, substance use, noncompliance, impaired judgment) satisfies clear and convincing standard | Affirmed: evidence supported finding K.J. gravely disabled and dangerous to herself; commitment continued |
| Constitutionality of Indiana Code ch.12-26-15 (no automatic annual-review hearing) | K.J.: statute violates due process by placing burden on committed person to request hearing rather than requiring automatic hearing | State: statute provides required notice and an opportunity to be heard upon request, satisfying due process; hearing procedures and notice are adequate | Affirmed: statute constitutional; due process requires notice and opportunity to be heard, not an automatic hearing every year |
Key Cases Cited
- Golub v. Giles, 814 N.E.2d 1034 (Ind. Ct. App. 2004) (standard for reviewing sufficiency of evidence in commitment proceedings)
- M.Z. v. Clarian Health Partners, 829 N.E.2d 634 (Ind. Ct. App. 2005) (commitment requires clear and convincing proof of mental illness and dangerousness or grave disability)
- Civil Commitment of W.S. v. Eskenazi Health, Midtown Cmty. Mental Health, 23 N.E.3d 29 (Ind. Ct. App. 2014) (due process and standards for civil commitment)
- T.A. v. Wishard Health Servs., 950 N.E.2d 1266 (Ind. Ct. App. 2011) (interpretation of gravely disabled disjunctive elements)
- A.L. v. Wishard Health Servs., 934 N.E.2d 755 (Ind. Ct. App. 2010) (gravely disabled analysis)
- In re Matter of Tedesco, 421 N.E.2d 726 (Ind. Ct. App. 1981) (initial-detention hearing timing and due process; distinguished in this case)
- Ind. State Bd. of Educ. v. Brownsburg Cmty. Sch. Corp., 842 N.E.2d 885 (Ind. Ct. App. 2006) (due process requires notice and opportunity to be heard)
- In re M.L.K., 751 N.E.2d 293 (Ind. Ct. App. 2001) (notice must be reasonably calculated to inform and allow response)