Articles and Blogs

The Indiana Court of Appeals recently affirmed a regular commitment to a state hospital of a gravely disabled patient based on evidence that the patient’s symptoms impaired his judgment and his refusal to take medication and behavior demonstrated his inability to function independently. In re Commitment of G.S. v. Richmond State Hosp., No. 25A-MH-2033,... READ MORE

The Indiana Court of Appeals (the “Court”) confirmed that evidence about the patient’s indirect threats of physical and sexual violence can satisfy the Petitioner’s burden to clearly and convincingly prove that the patient is dangerous. In re Commitment of W.C. v. Richmond State Hosp., 272 N.E.3d 983 (Ind. Ct. App. 2025) (unpublished table opinion).... READ MORE

The Indiana Court of Appeals (the “Court”) affirmed the trial court’s regular commitment of a patient whose mental illness stemmed from a traumatic brain injury (“TBI”). In its reasoning, the Court connected the past event to the patient’s current aggressiveness, emotional outbursts, inability to provide for basic needs and lack of insight into illness... READ MORE

The Indiana Court of Appeals (the “Court”) recently affirmed a trial court’s finding of grave disability, reiterating two settled principles: (1) no single fact can establish grave disability; and (2) courts must evaluate the totality of the circumstances. The Court also confirmed that past conduct with a nexus to the patient’s current condition may... READ MORE

The Indiana Supreme Court (the “Court”) upheld a trial court’s Order for Temporary Commitment, reaffirming the new mootness standard for temporary civil commitment appeals first established earlier this year in In re Commitment of J.F., 256 N.E.3d 1260 (Ind. 2025). In re Commitment of M.C., 262 N.E.3d 836 (Ind. 2025). Background In J.F., the Court... READ MORE

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

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

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

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

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