Articles and Blogs

The Indiana Court of Appeals (the “Court”) affirmed the trial court’s order for a temporary commitment which authorized forcibly medicating the patient. The Court held that the hospital presented clear and convincing evidence, primarily through detailed physician testimony, that both commitment and involuntary medication are appropriate. In re Commitment of L.F., No. 26A-MH-658, 2026... READ MORE

The Indiana Court of Appeals (the “Court”) affirmed a trial court’s determination that a patient was gravely disabled—even though he initially sought care for a physical ailment. The Court held that the patient’s refusal of necessary treatment, combined with his lack of insight into both his medical and psychiatric conditions, satisfied the clear-and-convincing-evidence standard.... READ MORE

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 App. 2025) (unpublished table opinion)....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

In a recent decision, the Indiana Court of Appeals (the “Court”) upheld a trial court’s Order for Temporary Commitment and affirmed a new mootness standard for civil commitment appeals. In re Commitment of J.F., 266 N.E.3d 268 (Ind. Ct. App. 2025). Background The Indiana Court of Appeals reaffirmed its standard for what evidence is... 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”) affirmed a trial court’s order for a regular involuntary commitment, holding that when clear and convincing evidence shows treatment would likely extend past 90 days, regular commitment is appropriate. In re Commitment of D.W., No. 24A-MH-2284 (Ind. Ct. App., May 30, 2025). Background D.W., 46, voluntarily presented... READ MORE