State, 12-17-00174-CV

Appellant (B.D.) was found incompetent to stand trial and committed to Rusk State Hospital under Chapter 46 to restore competency.
Appellant refused prescribed psychoactive medication, claiming it was heroin and that staff were "trying to drug" him.
The State filed for a court order to administer psychoactive medication over Appellant’s refusal; Appellant did not appear at the hearing.
Dr. Stephen Poplar, the treating physician, entered his written application into evidence and testified briefly: diagnosing schizoaffective disorder/psychosis, stating Appellant lacked capacity, and opining that medication was in Appellant’s best interest and would expedite competency restoration.
Dr. Poplar did not testify about key best-interest factors at the hearing: the specific consequences of withholding medication, a prognosis with treatment, or reasonable, less-intrusive alternatives.
The trial court granted the order; the court of appeals reversed, holding the evidence legally insufficient to support the best-interest finding and rendering judgment denying the State’s application.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to find medication was in patient’s best interest	Dr. Poplar’s testimony and written application show benefits, lack of capacity, and faster competency restoration	Evidence was only conclusory; physician failed to testify on consequences of no treatment, prognosis with treatment, or less-intrusive alternatives	Reversed — legal insufficiency: doctor’s perfunctory testimony and application alone could not satisfy clear-and-convincing standard

Addington v. Texas, 588 S.W.2d 569 (Tex. 1979) (defines clear-and-convincing standard required)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standards for appellate review of clear-and-convincing evidence)
State ex rel. E.G. v. B.B., 249 S.W.3d 728 (Tex. App.—Tyler 2008) (conclusory physician statements/application insufficient to prove best interest)
In re E.T., 137 S.W.3d 698 (Tex. App.—San Antonio 2004) (State must prove lack of capacity and best interest; physician testimony required)
State ex rel. D.W., 359 S.W.3d 383 (Tex. App.—Dallas 2012) (contrast: sufficient when physician detailed benefits, risks, and lack of alternatives)