In a move not typically seen, the Indiana Court of Appeals extended a Hoosier woman’s temporary involuntary commitment solely based on an eating disorder that doctors said was causing her severe malnutrition.
Members of an appellate panel in a Dec. 16 memorandum decision affirmed the commitment of Y.K., who was diagnosed with the eating disorder anorexia nervosa, finding sufficient evidence that she was both mentally ill and gravely disabled. Anorexia nervosa, also known simply as anorexia, is an eating disorder characterized by an abnormally low body weight, an intense fear of gaining weight and a distorted perception of weight, according to the Mayo Clinic.
“I’ve not seen other commitment cases grounded solely in anorexia,” Joel Schumm, an Indiana University Robert H. McKinney School of Law professor, said after looking at the case of In Re: The Involuntary Commitment of Y.K. v. Deaconess Hospital, April Toelle and Selah House, 20A-MH-1116. Schumm also heads the appellate clinic at IU McKinney.
When Y.K. was admitted to the Deaconess Midtown emergency room in Evansville in January 2020 due to swelling in her lower extremities, she weighed 66 pounds. Determining that the swelling had developed due to complications associated with malnutrition, Deaconess filed an application for emergency detention of Y.K., which was approved by the Vanderburgh Superior Court.
Dr. Hemapriya Reddy diagnosed Y.K. with an eating and psychiatric disorder, specifically, anorexia nervosa, and noted that Y.K.’s eating disorder was “causing harm to [her]self [,] causing severe malnutrition, and complications[.]” Given her age and height, the physician concluded a normal weight would be “around 105, 110 pounds[.]”
Deaconess filed to temporarily commit Y.K., who disagreed with her diagnosis and argued that she had a passion for health and taking care of her body. The trial court subsequently granted a petition for Y.K.’s temporary commitment with approval for transfer to the Indiana University Medical Center.
After receiving Y.K. from the Indiana University Medical Center, Selah House filed a physician’s statement and report requesting extension of temporary commitment for Y.K. Dr. Thomas Scales, who had performed Y.K.’s psychiatric assessment at Selah House and diagnosed her with a psychiatric disorder called “avoidant restrictive food intake disorder,” signed the physician’s statement.
The trial court, finding that Y.K. suffered from a mental illness and was a danger to herself and gravely disabled, ultimately ordered that her temporary commitment be extended.
The Indiana Court of Appeals affirmed, concluding that there was sufficient evidence that as a result of Y.K.’s mental illness, she was gravely disabled for purposes of her involuntary temporary commitment. It rejected her argument that there was no evidence presented that she was “unable to provide herself with clothing, shelter, or other essential human needs[,]” including food.
“Part of the grave disability determination may involve an inability to provide food, which comes up occasionally in commitment cases, often coupled with other concerns,” Schumm told IL.
“When Y.K. was first admitted to a hospital, she weighed 66 pounds and exhibited swelling in her lower extremities,” Judge Rudolph Pyle III wrote for the unanimous appellate panel. “The hospital determined that Y.K.’s swelling had developed due to complications associated with malnutrition. After three months of inpatient treatment, Y.K.’s weight had increased to 84 pounds.
“However, Dr. Scales explained that Y.K. continued to be ‘very underweight’ and that her weight was ‘approximately 60% of her ideal body weight[.]’ Dr. Scales opined that Y.K.’s eating disorder had ‘resulted in her having significant weight loss and having actually really severe medical complications[.]’ When asked whether he believed Y.K. could provide for herself, Dr. Scales explained that Y.K. was not caring for herself by providing basic nutritional needs,” Pyle continued.
“Furthermore, although Dr. Scales stated that Y.K. had some insight into her mental illness, he explained that he did not believe that she fully grasped the severity of the risks associated with her eating disorder,” the appellate panel concluded.•