State, 12-16-00231-CV

J.L., subject to a Chapter 46B court order for inpatient mental-health services, was the target of an application by his treating physician, Dr. Stephen Poplar, seeking a court order authorizing the Texas Department of State Health Services to administer multiple classes of psychoactive medications.
Poplar’s sworn application and hearing testimony diagnosed J.L. with bipolar I disorder, most recent episode manic, severe, with psychotic features; Poplar testified J.L. refused medications and lacked insight into his illness.
Poplar recommended antidepressants, antipsychotics, mood stabilizers, and anxiolytics/sedatives/hypnotics, concluding benefits outweighed risks and less intrusive alternatives were unlikely to produce comparable results.
At the hearing, Poplar testified to J.L.’s symptoms (pressured speech, tangential thinking, persecutory delusions, unrecognized auditory hallucinations, mood lability), prior psychiatric hospitalization with prior response to meds, and inability to rationally weigh risks/benefits.
J.L. testified he did not have a mental illness, refused the proposed medications, and recounted prior hospitalization experiences; he did not claim religious objections or identify specific side-effect concerns.
The trial court found by clear and convincing evidence that J.L. lacked capacity to decide about the medications and that treatment was in his best interest; the court authorized administration of the medications. J.L. appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to show J.L. lacked capacity to decide about psychoactive medication and that treatment was in his best interest	J.L. contended the State failed to prove by clear and convincing evidence that he lacked capacity or that proposed treatment was in his best interest	The State (via Poplar) argued J.L. lacked insight, displayed psychotic/manic symptoms, had prior positive response to meds, resisted rational discussion of risks/benefits, and that benefits outweighed risks with less intrusive alternatives unlikely to succeed	Court affirmed: evidence legally and factually sufficient to support findings that J.L. lacked capacity and that proposed medication treatment was in his best interest

In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standard for reviewing legal sufficiency under clear-and-convincing-evidence burden)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (standard for reviewing factual sufficiency when clear-and-convincing evidence required)
State v. Addington, 588 S.W.2d 569 (Tex. 1979) (definition of “clear and convincing evidence”)