The Indiana Court of Appeals (the “Court”) upheld the trial court’s Order for Regular Commitment because sufficient evidence supported the finding that the patient, B.C., was both dangerous and gravely disabled. In re: the Civil Commitment of B.C., No. 25A-MH-303, 266 N.E.3d 304 (Ind. Ct. App. 2025).
Background
B.C., diagnosed with schizophrenia, was incarcerated in May 2024. During his incarceration, he went extended periods without eating or drinking, which ultimately led to his hospitalization and subsequent transfer to the prison’s mental health unit. B.C. also suffered from “prominent symptoms of disorientation,” including paranoia and disorganized speech or periods of mutism, was aggressive towards mental health staff and refused medication. The trial court granted the correctional facility’s petition for regular commitment in January 2025, and B.C. was committed to a state hospital.
On appeal, B.C. argued the evidence at trial was insufficient to support findings that (1) he was either dangerous or gravely disabled; and (2) his commitment to the state hospital was appropriate.
Analysis of Dangerous or Gravely Disabled
The Court affirmed the finding that B.C. was gravely disabled and dangerous, even though the disjunctive test only requires proving one, because of his threats to assault staff, his extended periods without eating or drinking and his refusal to take medication. The Court also noted B.C.’s commitment was appropriate because he lacked insight into his illness.
B.C. argued that his refusal to take medication and his denial of his diagnosis “standing alone” are insufficient to prove grave disability. However, the Court emphasized the Petitioner did not present evidence of any one factor “standing alone.” Instead, the trial court considered evidence from B.C.’s physician, who testified that B.C.’s symptoms of disorientation worsened after his noncompliance with medication and that B.C. would be unable to provide for his basic necessities if released. The physician cited B.C not knowing his name, that he was incarcerated or that his release was soon during these periods of disorientation.
B.C. also argued that the evidence did not demonstrate the “immediacy” of his dangerousness. However, the Court further disagreed. B.C. primarily cited his recent medication change to a different antipsychotic medication. However, B.C.’s past behavior of threatening to assault staff, grab them through the cuff port and throw items at them demonstrated his dangerousness. The Court also noted it will not reweigh the evidence. Thus, the correctional facility provided sufficient evidence to support B.C.’s regular commitment.
Practical Takeaways
- Threats of Assault Can Prove Dangerousness: An individual does not have to physically batter another person to meet the threshold for dangerousness. Instead, evidence of repeated threats of assault, including threatening to grab someone through a cuff port or throw items at them, meets this standard.
- Refusal to Take Medication and Denial of Illness Can Support a Finding of Grave Disability: An adequate showing of refusal to take medication and the denial of one’s illness, alongside sufficient evidence, supports the finding of grave disability.
- Appellate Courts Do Not Reweigh Evidence: The trial court is the fact finder. An appellate court will not reweigh the evidence, even if a party requests it.
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.
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