An Indianapolis woman was improperly ordered committed for mental illness, but there was insufficient evidence she was gravely disabled, a panel of the Indiana Court of Appeals ruled Monday. The decision further emphasizes the need for clear and convincing evidence of grave disability to support a commitment.
“The only evidence in the record supporting (T.D.’s) commitment was one isolated incident of unusual behavior, the fact that T.D. lived in a hotel, her psychiatrist’s recommendation and her refusal to seek treatment,” Judge Rudolph R. Pyle III wrote for the panel. “Because this did not constitute clear and convincing evidence to support her involuntary commitment, we reverse the trial court’s decision and remand to the trial court to vacate the commitment.”
According to the record in In the Matter of the Civil Commitment of T.D. v. Eskenazi Health Midtown Community Mental Health Center, 49A05-1411-MH-529, T.D., 51, had a history of treatment for bipolar disorder and previously had been committed. After she was released from care, the record says, she was preparing a presentation for a large event when she “flooded her hotel room with water and steam, intending to set off the fire alarms so that the fire department would come to the hotel and help her prepare for the event.”
This led to the hospital seeking emergency detention, which was granted due to the hotel incident and a doctor’s testimony regarding T.D.’s need for treatment. But the panel found this insufficient to prove grave disability as required under I.C. § 12-7-2-96. The ruling also cited the U.S. Supreme Court case Addington v. Texas, 441 U.S. 418 (1979).
“Our Indiana Supreme Court recently echoed the Addington Court’s caution against unnecessary commitments in Civil Commitment of T.K.,” Pyle wrote. “There, our supreme court disapproved of multiple Court of Appeals decisions affirming commitments and emphasized that there must be a higher standard of clear and convincing evidence to support a regular commitment.”
“The hotel incident was one isolated incident, and, while T.D.’s actions at the hotel were unusual, she did not harm herself or anyone else. Because the only evidence the Hospital presented at trial did not constitute clear and convincing evidence to support T.D.’s commitment, we reverse the trial court’s decision and remand for the trial court to vacate the regular commitment,” the panel concluded.