M.L. v. Meridian Services, Inc.
2011 Ind. App. LEXIS 1865
| Ind. Ct. App. | 2011Background
- M.L. suffers from alcoholism and depression; he threatened suicide and drank rubbing alcohol, leading to emergency detention. Meridian petitioned for a 90-day involuntary commitment to a state facility and for authority to administer medication. The trial court granted the petition and authorized medication (Celexa and Neurontin). M.L. challenged both the basis for commitment and the medication authorization. The trial court relied on Dr. Khadilkar’s testimony that M.L. was dangerous to himself and gravely disabled. The appellate court affirmed the temporary commitment but reversed the medication authorization for lack of supporting evidence on benefits and least-restrictive alternatives.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was clear and convincing evidence M.L. was dangerous or gravely disabled. | Meridian failed to prove danger/gravely disabled | M.L. was dangerous and gravely disabled due to alcohol dependence and depression | Yes, dangerous; evidence insufficient for gravely disabled conclusion (only need dangerous). |
| Whether there was clear and convincing evidence medications would substantially benefit M.L. and outweigh risks. | Medications will substantially benefit and benefits outweigh risks | Medications supported by medical assessment | No; insufficient evidence of substantial benefit or least-restrictive treatment; reversed medication authorization. |
Key Cases Cited
- M.M. v. Clarian Health Partners, 826 N.E.2d 90 (Ind.Ct.App.2005) (sufficiency standard for commitment evidence remains deferential to trial court)
- A.L. v. Wishard Health Servs., Midtown Cmty. Mental Health Ctr., 934 N.E.2d 755 (Ind.Ct.App.2010) (clear and convincing standard for commitment; dangerous or gravely disabled must be proven)
- J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448 (Ind.Ct.App.1991) (no liberty confinement absent dangerousness or grave disability)
- G.Q. v. Branam, 917 N.E.2d 703 (Ind.Ct.App.2009) (time limits and due process in temporary commitment; treatment considerations)
- In re Mental Commitment of M.P., 510 N.E.2d 645 (Ind. 1987) (liberty interest and standards for forced medication)
- G.M. v. Indiana Ct. of App., 743 N.E.2d 1148 (Ind.Ct.App.2001) (consideration of alternatives and restrictions in treatment orders)
- J.S. v. Ctr. for Behavioral Health, 846 N.E.2d 1106 (Ind.Ct.App.2006) (requirements for court-authorized forced treatment)
- S.T. v. Cmty. Hosp. N., 930 N.E.2d 684 (Ind.Ct.App.2010) (totality of circumstances in evaluating commitment)