COA affirms woman’s involuntary commitment despite moot appeal

Although the term of her commitment in an Indiana mental health facility had already expired, the Indiana Court of Appeals chose Thursday to hear a woman’s moot appeal of her commitment and affirm it, writing that the case needed to be heard as a matter of great public importance.

After Dr. Lynnea T. Carder, a mental health professional, testified in August 2015 that J.M. had been diagnosed with schizoaffective disorder, refused to take medicine and had acted belligerently toward the staff of Northeastern Center Inc. and her family, the Steuben Superior Court found that J.M. was gravely disabled by a severe mental illness and ordered that she be committed for no more than 90 days at Northeastern.

J.M. appealed her involuntary commitment, but did so after the 90-day commitment had expired, making her case moot. However, in a Thursday opinion, a panel of the Indiana Court of Appeals wrote that J.M.’s case was one of “great public importance” and, thus, could be addressed on the merits.

In her appeal, J.M. argued that Northeastern failed to present sufficient evidence to support her involuntary commitment by failing to prove that she is dangerous, as is required for involuntary commitment under Indiana statute. The term “dangerous” is defined under the statute as “a condition in which an individual as a result of mental illness presents a substantial risk that the individual will harm the individual or others.”

Because there had been no discussion in court of J.M. making any threats or violent actions, she argued that Northeastern had not proven that she was “dangerous.”

But the Court of Appeals disagreed, writing that Carder’s testimony could cause a reasonable fact-finder to believe that J.M. presented a substantial risk to herself and to other because of her mental illness. Specifically, Carder had testified that J.M. had acted delusional and hallucinatory, had made threats to her family and that her family was scared of J.M. Further, the doctor testified that her patient had made threats to the Northeastern staff.

Thus, the Court of Appeals wrote that the evidence supported J.M.’s involuntary commitment.  The case is In The Matter of the Commitment of J.M., J.M. v. Northeastern Center, Inc., 76A05-1509-MH-1477,