Articles and Blogs

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

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

In In Re: Commitment of M.C., the Indiana Court of Appeals (the “Court”) dismissed M.C.’s appeal as moot because M.C. failed to demonstrate a particularized collateral consequence of his commitment or that the Indiana Constitution compelled the Court to hear his appeal on the merits. No. 24A-MH-1364, 2025 WL 658771 (Ind. Ct. App. Feb. 28, 2025).... READ MORE

In In Re: Commitment of G.M., the Indiana Court of Appeals (the “Court”) affirmed the trial court’s refusal to allow a patient to waive the right to counsel in commitment proceedings. No. 24A-MH-2677, 2025 WL 928559 (Ind. Ct. App. Mar. 27, 2025). The decision highlighted the importance of civil commitment proceedings, the effect of... READ MORE

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

In Re: Civil Commitment of K.K., the Indiana Court of Appeals (the “Court”) dismissed K.K.’s appeal on the basis of mootness, as K.K.’s temporary commitment expired in August 2024. The Court analyzed its mootness standard and the applicability of the public interest exception to the case. Background Under Indiana law, a hearing for involuntary commitment must... READ MORE

In R.R. v. Richard L. Roudebush Veterans Affairs Medical Ctr. (“R.R.“), the Indiana Court of Appeals (the “Court”) upheld a trial court’s decision to place a patient diagnosed with schizoaffective disorder under regular commitment. The Court applied the disjunctive test for “gravely disabled” and clarified that a patient’s profound disorganization which hinders the patient’s... READ MORE