In R.R. v. Richard L. Roudebush Veterans Affairs Medical Ctr. (“R.R.“), the Indiana Court of Appeals (the “Court”) upheld a trial court’s decision to place a patient diagnosed with schizoaffective disorder under regular commitment. The Court applied the disjunctive test for “gravely disabled” and clarified that a patient’s profound disorganization which hinders the patient’s “independent functioning” can justify commitment.
Background
Indiana only authorizes involuntary commitment of patients suffering a mental health crisis if clear and convincing evidence proves: (1) the individual is mentally ill; (2) is either dangerous or gravely disabled; and (3) commitment is appropriate. Gravely disabled is the statutory term for when the patient’s mental illness prevents them from adequately caring for themselves. The Court offered guidance on what meets this test.
The Court’s Analysis of Gravely Disabled
In R.R., the trial court granted regular commitment of a patient diagnosed with schizoaffective disorder. On appeal, R.R. challenged whether clear and convincing evidence proved she was gravely disabled and that her commitment was appropriate.
R.R. argued the evidence did not clearly and convincingly establish she was unable to provide for her own essential human needs or unable to function independently. The Court disagreed, emphasizing that the trial court is best situated to weigh the evidence at a hearing, and concluded that clear and convincing evidence proved R.R. was so profoundly disorganized as to be unable to function independently.
Specifically, the Court found R.R.’s testimony confusing, tangential, irrelevant and incoherent. R.R.’s disorganized thought process hindered her ability to think clearly, engage in goal-directed activity, plan and problem-solve. Thus, the Court found her testimony reflected the severe impact of her psychosis and mania on her ability to function independently, upholding the trial court’s finding of grave disability.
Practical Takeaways
The Court analyzed the test for grave disability and emphasized:
- Independent Functioning: Evidence showing a patient cannot consistently maintain housing, despite having the financial ability to do so, supports a finding of grave disability.
- Disorganized Testimony: Evidence that a patient’s profound disorganization impairs their ability to function independently supports a finding of grave disability. Such evidence can come from the trial court’s own assessment of the patient’s testimony.
- Appropriateness of Commitment: Evidence of disorganized thinking, poor medication adherence, limited insight and history of decompensation after commitment clearly and convincingly established that regular commitment was appropriate, notwithstanding R.R.’s limited improvement during hospitalization.
If you have questions or would like more information about this topic, please contact:
- Ryan McDonald at (317) 429-3671 or rmcdonald@hallrender.com;
- Kennedy Bunch at (317) 977-1420 or kbunch@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
