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In a shift that strengthens due process rights for individuals facing temporary civil mental health commitments, the Indiana Supreme Court has ruled that appeals of expired commitments are not moot if any potential collateral consequences remain.
The decision in J.F. v. St. Vincent Hospital and Health Care Center, Inc., issued May 5, resolves longstanding inconsistencies in how Indiana appellate courts have handled these appeals and ensures that most individuals committed for up to 90 days will have their cases heard on the merits—even after their release.
“Temporary commitments—like criminal convictions and CHINS judgments—implicate both substantial liberty interests and lifelong collateral consequences,” Chief Justice Loretta Rush wrote for the majority. “We give meaning to the Legislature’s specific guarantee of the right to appeal temporary commitment orders by holding that the order’s expiration does not moot a timely appeal unless the appellee establishes the absence of any collateral consequences.”
Broader implications
The ruling clarifies that individuals appealing a temporary commitment do not lose their right to appellate review simply because their confinement ends before the case is decided—a common occurrence given the time limits involved. The court cited firearms restrictions, future commitment risks, stigma, and access to housing, employment, or child custody as examples of ongoing consequences that can follow a civil commitment.
Until now, the Indiana Court of Appeals had used previous case law that set up a case-by-case approach based on either the “public interest exception” or the existence of “particularized harmful consequences.” This had led to uneven outcomes—some panels reached the merits; others dismissed appeals as moot.
“The inconsistent resolution of these appeals has also bred inefficiency by requiring attorneys and judges to routinely spend substantial resources litigating and deciding mootness issues,” the opinion said.
Under the new standard, mootness will only apply if the hospital or treatment provider can prove the absence of any collateral consequence—a high bar. The goal is to refocus legal efforts on “the essential issues of liberty and public safety.”
The case at hand
The court’s decision arose from the case of J.F., a woman in her late 30s who was temporarily committed to the St. Vincent Stress Center in early 2023 following delusions and erratic behavior that included living outdoors in freezing temperatures. A trial judge found clear and convincing evidence she was “gravely disabled” and authorized a 90-day commitment.
Although her commitment ended before the appeal was fully briefed, J.F. asked the Indiana Court of Appeals to consider her case anyway.
That court dismissed it as moot, reasoning the appeal didn’t raise novel or complicated legal questions. The Indiana Supreme Court disagreed, granted transfer, and affirmed the trial court’s original ruling after reviewing the evidence on its merits.
Cautions
Justice Geoffrey Slaughter concurred in the result but criticized the majority’s continued use of the “public interest exception” to mootness. He argued that only disputes involving live parties and real consequences should be decided under the Indiana Constitution’s separation of powers.
Slaughter also noted that the court’s ruling shifts its burden of proving mootness from the committed person to her custodian, which he has no issue with, but states that reassigning the burden between parties does not relieve the court of its independent duty to ensure the matter remains “a live, justiciable controversy.”
Still, Slaughter agreed with the central holding: that J.F.’s case remained justiciable due to the likelihood of future harm stemming from her expired commitment.
The opinion likely will significantly reduce the number of commitment appeals dismissed as moot in Indiana and aligns the state with jurisdictions like Massachusetts, Texas, and Alaska that provide broad review of expired mental health commitments.
The court also noted a related pilot project in Marion County that is experimenting with expedited appeals in these cases using advanced transcription technology and accelerated briefing. That effort aims to resolve some appeals within 90 days—before commitments expire.
Attorneys for J.F. included Joel Schumm, a professor at the Indiana University Robert H. McKinney School of Law, and Talisha Griffin of the Marion County Public Defender Agency. St. Vincent Hospital was represented by Andrew Howk and Matthew Schappa of Hall Render. Several amici, including the ACLU of Indiana, Community Health Network, and the Indiana Public Defender Council, filed briefs highlighting the systemic impact of commitment appeals.
The case is In the Matter of the Civil Commitment of J.F. v. St. Vincent Hospital and Health Care Center, Inc., 25S-MH-111.
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