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State
12-17-00098-CV
| Tex. App. | Aug 9, 2017
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Background

  • 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)
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Case Details

Case Name: State
Court Name: Court of Appeals of Texas
Date Published: Aug 9, 2017
Docket Number: 12-17-00098-CV
Court Abbreviation: Tex. App.