Peo in Interest of Kreidler
24CA1178
| Colo. Ct. App. | Sep 12, 2024Background
- Richard Dana Kreidler was civilly committed to the Colorado Mental Health Hospital in Pueblo (CMHHIP) after being found permanently incompetent to proceed in a criminal case due to chronic psychosis.
- He has been diagnosed with schizoaffective disorder, bipolar type, exhibiting delusions, mood shifts, and response to internal stimuli.
- Criminal charges against Kreidler were dismissed, but he remains hospitalized on civil commitment, assessed as gravely disabled and dangerous to others.
- Kreidler repeatedly refused prescribed antipsychotic and mood stabilizing medications, resulting in multiple petitions for involuntary medication.
- The district court held an evidentiary hearing, where Kreidler and Dr. Charles Dygert (his attending psychiatrist) testified, and subsequently authorized involuntary administration of certain medications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient to meet the fourth Medina factor for involuntary meds? | Kreidler argued no compelling need exists; | The People argued Kreidler lacked a bona fide reason for refusal and needs medication. | The court found compelling need for meds, no legitimate interest in refusal, order upheld. |
| bodily autonomy and past side effects cited. |
Key Cases Cited
- People v. Medina, 705 P.2d 961 (Colo. 1985) (establishes four-factor test for involuntary administration of antipsychotic medication)
- People v. Pflugbeil, 834 P.2d 843 (Colo. App. 1992) (psychiatric testimony may suffice for involuntary med orders)
- People in Interest of A.J.L., 243 P.3d 244 (Colo. 2010) (appellate court may not substitute its judgment for district court if record supports findings)