In a recent decision, the Indiana Court of Appeals (the “Court”) upheld the trial court’s Order for Temporary Commitment, clarifying that a finding of “dangerousness” for civil commitment is not negated by claims of self-defense when the underlying conduct is driven by delusional beliefs. In re Commitment of J.S., No. 25A-MH-979, 263 N.E.3d 165 (Ind. Ct. App. 2025). The Court also reaffirmed the collateral consequences exception to the mootness doctrine.
Background
J.S., diagnosed with an unspecified psychotic disorder, presented with manic behavior, disorganized thoughts and paranoid delusions. At the hospital, J.S. made homicidal statements. But when asked about these statements, she testified she thought her life was in danger. The trial court granted the hospital’s petition for temporary involuntary commitment.
At the hearing, J.S. testified that she had been persecuted by a methamphetamine dealer, assaulted by shelter residents conspiring to kill her and forced into prostitution under threats of violence. She denied experiencing psychosis and refused medications. When asked about her ability to care for herself, J.S. described strategies for obtaining food, such as getting food “from the floor” or “via osmosis.”
On appeal, J.S. challenged the trial court’s findings that she suffered from a mental illness, was gravely disabled and was dangerous, arguing that they were unsupported by clear and convincing evidence.
Analysis of Mental Illness and Grave Disability
The Court affirmed the finding that J.S. was mentally ill, noting her delusions, paranoia and manic presentation met this threshold. The Court also stated that J.S.’s own testimony highlighted her mental illness.
Further, the Court held that J.S.’s pattern of persecutory delusions and violent ideation—conduct she framed as self-defense—rendered her dangerous due to her mental illness. The Court also upheld the finding that J.S. was gravely disabled. She lacked insight into her condition, inconsistently took medication and described delusional coping strategies for obtaining food (e.g., “osmosis”). Her inability to reliably meet her basic needs and function independently satisfied the statutory test.
Procedural Note on Mootness
Although J.S. had been discharged prior to appeal, the Court rejected the hospital’s mootness argument. Citing prior caselaw, the Court held that temporary commitment appeals generally remain viable unless the appellee makes an extraordinary showing that no collateral consequences remain—a showing the hospital did not make.
For a detailed discussion on mootness and collateral consequences in Indiana civil commitment appeals, see Hall Render’s analysis here.
Practical Takeaways
- Preventive Commitment Based on Delusional Risk Is Permissible: Indiana courts may uphold temporary civil commitment when credible evidence shows a substantial risk of harm stemming from delusional beliefs, even if no actual violence has occurred. Threats, even when framed as self-defense, satisfied the statutory definition of “dangerousness” when rooted in delusional beliefs.
- Courts Are Concerned with Mootness: The Indiana Supreme Court and Court of Appeals are concerned with how the mootness doctrine (and its limited exceptions) impacts patients who are temporarily committed. A recent Indiana Supreme Court decision stated that the expiration of a temporary commitment does not render an appeal moot unless no collateral consequences exist.
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.
