The Indiana Court of Appeals (the “Court”) recently reiterated that trial courts may not impose “special conditions” in civil commitment orders without record evidence tying the condition to the patient’s treatment or public safety. The Court invalidated a trial court’s blanket prohibition on alcohol and non-prescription drugs, finding no evidentiary basis for the restriction. In Re: Commitment of C.M., 258 N.E.3d 280 (Table), 2025 WL 944745 (Ind. Ct. App. Mar. 28, 2025) (unpublished).
Background
In October 2024, C.M. entered a church unclothed and stated that God had instructed him to harm himself. Law enforcement transported him to a local hospital, where a psychiatrist conducted a clinical evaluation. The psychiatrist observed that C.M. exhibited religious preoccupation, disorganized thinking, impaired insight and a lack of awareness of his mental health needs. C.M. was diagnosed with schizoaffective disorder and admitted for inpatient psychiatric treatment.
The hospital sought temporary commitment, which the trial court granted after a hearing. The trial court’s order also included a special outpatient condition prohibiting C.M. from using alcohol or non-prescription drugs upon transitioning to outpatient status. The trial court imposed this condition based on a preprinted form submitted by the hospital physician, which contained no individualized justification for the restriction.
C.M. initially filed an untimely appeal through Indiana’s Pilot Program for expedited mental health appeals before pursuing a regular appeal, arguing that (1) the order for commitment was not supported by sufficient evidence and (2) the special condition lacked a factual foundation in the record.
The Court’s Analysis
Because the commitment had expired and C.M. did not argue that the issue was capable of repetition yet evading review, the Court declined to consider the sufficiency of the evidence supporting the commitment. However, the Court did consider whether the commitment order’s special condition was supported by sufficient evidence, finding it a question of public interest and therefore an exception to the mootness doctrine.
The Court first noted the statute authorizes special outpatient conditions that are reasonably related to the individual’s treatment needs or public safety. I.C. § 12-26-14-3. However, the Court emphasized that Indiana law only authorizes those special outpatient conditions when the need for them is supported by sufficient evidence and:
[T]here must be sufficient evidence in the record for the trial court to conclude that such a “special condition” bears a reasonable relationship to the treatment of the individual and the protection of the individual and the public.
In re Commitment of G.H., 216 N.E.3d 485, 490 (Ind. Ct. App. 2023).
Since the hospital did not present evidence that C.M. had a history of alcohol or substance abuse, that such use would compromise C.M.’s treatment regimen, or otherwise support the proposed restriction, the Court held the preprinted form insufficient to justify a special condition. Accordingly, it reversed that portion of the trial court’s order.
Practical Takeaways
- Evidence Matters: Trial courts must rely on the evidence presented—not the court’s conclusions or speculation—when imposing special outpatient conditions.
- No Presumptive Conditions: Conditions like abstaining from alcohol or non-prescribed drugs cannot be presumed appropriate in every case. The evidence must demonstrate a clear link between the condition and the patient’s mental health or safety.
- Review Outpatient Terms: Hospitals and counsel should carefully tailor the proposed orders they submit to the trial court to each individual case and ensure any proposed special conditions are substantiated in the evidentiary record.
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 give legal advice outside of an attorney-client relationship.
