Articles and Blogs

Grave Disability

Indiana Appeals Court Clarifies Dangerousness Standard, Reaffirms Mootness Exception in Civil Commitment Case

[11/24/25]

Posted on November 24, 2025 in Litigation Analysis, Mental Health

Published by: Hall Render

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... READ MORE

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Indiana Court of Appeals Holds Repeated Threats and Disorientation Establish Dangerousness and Grave Disability

[11/17/25]

Posted on November 17, 2025 in Litigation Analysis, Mental Health

Published by: Hall Render

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... READ MORE

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Indiana Court of Appeals Emphasizes Trial Court’s Role in Credibility Determinations for Grave Disability Findings

[10/20/25]

Posted on October 20, 2025 in Health Law News, Mental Health

Published by: Hall Render

The Indiana Court of Appeals (the “Court”) in In re: the Civil Commitment of J.A. upheld the trial court’s Order for Temporary Commitment, holding sufficient evidence supported the trial court’s finding that J.A. was gravely disabled and unable to function independently outside of the hospital setting. In re: the Civil Commitment of J.A., No.... READ MORE

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Indiana Court of Appeals Holds Hospital Recidivism Coupled with Medication Noncompliance May Establish Grave Disability

[10/14/25]

Posted on October 14, 2025 in Health Law News, Mental Health

Published by: Hall Render

The Indiana Court of Appeals (the “Court”) in In re Commitment of G.J. emphasized the significance of hospital recidivism and catatonia as evidence and upheld the trial court’s Order for Temporary Commitment. No. 24A-MH-3101, 2025 WL 2438216 (Ind. Ct. App. 2025). Background G.J., diagnosed with schizophrenia, presented with symptoms of catatonia and periods of... READ MORE

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Indiana Court of Appeals Holds Suicidal Ideation and History of Suicide Attempts Establish Grave Disability

[03/21/25]

Posted on March 21, 2025 in Litigation Analysis, Mental Health

Published by: Hall Render

The Indiana Court of Appeals (the “Court”) in In re: the Civil Commitment of C.R. upheld the trial court’s Order for Regular Commitment, holding sufficient evidence supported the trial court’s finding that C.R. was dangerous to himself and gravely disabled. In re Commitment of C.R., No. 24A-MH-1485, 2024 WL 5153983 (Ind. Ct. App. Dec.... READ MORE

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Indiana Court of Appeals Affirms Regular Commitment of M.M. for Grave Disability 

[03/10/25]

Posted on March 10, 2025 in Health Law News, Mental Health

Published by: Hall Render

In Re: Commitment of M.M., (24A-MH-2046), the Indiana Court of Appeals (the “Court”) upheld the trial court’s order indefinitely committing M.M., ruling that sufficient evidence supported the finding that M.M. was gravely disabled. The decision underscores the legal standards for civil commitments and highlights the role of patient insight and independent functioning in determining... READ MORE

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