State
12-17-00098-CV
| Tex. App. | Aug 9, 2017Background
- Appellant R.L.J. was found incompetent to stand trial and committed to Rusk State Hospital under article 46B for restoration to competency.
- He refused prescribed psychoactive medication, denied mental illness, and ultimately refused to discuss medication.
- Treating physician Dr. Stephen Poplar submitted a sworn application recommending administration of psychoactive medication as the correct and most effective treatment to restore competency.
- A hearing was held; the trial court ordered administration of psychoactive medications under Tex. Health & Safety Code § 574.106.
- Appellant appealed, arguing the evidence was legally and factually insufficient to show (1) lack of capacity to decide about medication and (2) that medication was in his best interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence proved Appellant lacked capacity to decide about proposed psychoactive medication | Appellant: Evidence insufficient to show he lacked capacity to understand nature/consequences of treatment | State: Dr. Poplar’s testimony and application show Appellant denies illness, cannot rationally weigh risks/benefits, and refused treatment/discussion | Affirmed — evidence sufficient to find lack of capacity by clear and convincing evidence |
| Whether treatment with proposed medication was in Appellant's best interest | Appellant: Evidence insufficient that medication was in his best interest | State: Medication is the appropriate, most effective treatment; benefits outweigh risks; alternatives inadequate to restore competency | Affirmed — evidence sufficient that medication was in Appellant's best interest by clear and convincing evidence |
Key Cases Cited
- State v. Addington, 588 S.W.2d 569 (establishes the clear-and-convincing evidence standard)
- In re J.F.C., 96 S.W.3d 256 (explains legal and factual sufficiency review for clear-and-convincing-evidence findings)
- A.S. v. State, 286 S.W.3d 69 (patient lacks capacity if he does not understand nature of illness or necessity of medication)
