Court declines to review commitment cases differently

The Indiana Court of Appeals declined Thursday to change how it reviews cases dealing with involuntary commitment.

In The matter of the commitment of S.T. v. Community Hospital North, In-Patient Psychiatric Unit, No. 49A04-0910-CV-617, 23-year-old S.T., an Operation Iraqi Freedom veteran who uses a wheelchair, appealed her temporary involuntary commitment. Although the ordered up-to-90-day commitment has already passed, the appellate court addressed her appeal anyway.

S.T. tried to kill herself by overdosing on Tylenol. S.T suffered from post-traumatic stress disorder, a non-specific mood disorder, and attention deficit disorder. She also engaged in behavior associated with pica, an eating disorder in which people eat non-food items.

When staff tried to remove earrings from S.T.’s digestive tract, she ripped out her IVs and the procedure had to be stopped. She also was verbally abusive and threatening to staff members. After this, the trial court ordered the involuntary commitment.

The appellate court spent the majority of the opinion explaining why it would not reconsider the standard in which it reviews involuntary commitments, as S.T. urged.

S.T. argued for a de novo review, but the cases she cited don’t allow for the appellate court to usurp the trial court’s authority to weigh evidence and resolve factual disputes, or for the Court of Appeals to review sufficiency of evidence with no deference to the trial court, wrote Judge Melissa May.

“The determination of dangerousness under the involuntary commitment statute has always been a question of fact for the trial court to decide,” she wrote. “S.T. has not directed us to uncontroverted facts in the record that would change that determination into a question of law that we could review de novo.”

The appellate court also rejected the argument that a new standard should be adopted because the well-established one wasn’t being applied consistently. A review of 67 decisions over the last 25 years showed the opposite, noted the judge.

After explaining the standard in more detail, the appellate court affirmed S.T.’s commitment. Based on testimony from S.T. and the hospital, the court found three facts indicating she was a danger to herself: her behavior toward hospital staff due to her mental illness, her continued attitude of “hopelessness” about obtaining medication through Veterans Affairs, and the possibility of escalated risk of danger to herself as a result of pica.

Combining that with the fact she originally was admitted because of an overdose, she exhibited destructive and angry behavior while there and it was exacerbated by a nonspecific disorder and her PTSD, there was sufficient evidence to support her involuntary commitment for up to 90 days.