Commitment of M.M., Appellant-Respondent, v. Sandra Eskenazi Mental Health Center, Appellee-Petitioner. (2025)

MEMORANDUM DECISION

Statement of the Case

[1] M.M. has a chronic mental illness and arrived at the Sandra Eskenazi Mental Health Center (“the Center”) with head wounds and severe symptoms of psychological distress. The Center sought to have M.M. involuntarily committed for treatment, first on an emergency basis and then on an indefinite basis, to stabilize her symptoms.

[2] M.M. appeals the trial court's order committing her to the Center's care indefinitely. She argues the Center did not present sufficient evidence to sustain the trial court's order. Concluding that the evidence is sufficient, we affirm.

Facts and Procedural History

[3] M.M. has been diagnosed with schizo-affective disorder. According to M.M.’s psychiatrist at the Center, M.M.’s illness involves a mood component that “resembl[es] bipolar disorder and typically [has] manic episodes.” Tr. Vol. II, p. 11. Her illness also has “a psychotic component.” Id.

[4] M.M. has a long history of prior admissions to hospitals for mental health treatment, including involuntary commitments. She also received outpatient care from several providers, including the Center. In early 2024, M.M. was receiving outpatient care through the Center, but in May she stopped taking her prescribed medication.

[5] The current case began when M.M. arrived at the Center's emergency department in July 2024 with stab wounds on her scalp, face, and shoulder. The emergency department staff used ten sutures to close her head wounds. Next, the staff transferred M.M. to the psychiatric department because she appeared to be having “a manic episode and [a] psychotic episode[.]” Id. at 10.

[6] On July 17, 2024, the Center, by one of M.M.’s physicians, petitioned to detain M.M. on an emergency basis. The trial court granted the Center's petition and directed the Center to file a request for a hearing within seven days if M.M.’s physicians concluded a temporary or regular commitment was needed.

[7] M.M.’s treating psychiatrist at the Center determined she was “actively manic,” with disorganized, rambling speech and delusions. Id. at 11. She also displayed a disorganized thought process. Among other delusions, M.M. told her psychiatrist she had arrived at the emergency department for treatment of a bullet wound to her head.

[8] M.M. often ignored or dismissed questions from her treatment team about her condition and symptoms. In addition, M.M. initially refused to take any prescribed medicines, including injectable medications that she had previously accepted and supported. Four days after her admission, she began to take oral medications but continued to reject injectables. M.M.’s psychiatrist noted some improvement in her symptoms after she began taking oral medications. But she consistently denied having a mental illness and repeatedly claimed she did not need any doctors or medications.

[9] M.M. could not tell her treatment team where she planned to live after being discharged or how she would perform activities of daily living. She had been homeless for a period of time before her hospitalization. Her psychiatrist determined she could not function independently because of the untreated symptoms of her mental illness. He added that her diagnosis is a chronic condition that would require continued inpatient treatment to stabilize.

[10] On July 23, the Center petitioned for a final hearing to determine whether M.M. should be committed to the Center's care on an indefinite basis. The Center alleged M.M. was gravely disabled and required continuing treatment.

[11] The court held a hearing on July 30. M.M. testified, denying she had a mental illness or needed medication. She also denied that her psychiatrist had asked her about potential living situations after discharge.

[12] The court issued an order committing M.M. to the Center for an indefinite period, to end when: (1) the Center discharges M.M.; or (2) the court terminates the commitment. The court stated: “[M.M.] is gravely disabled in her judgment and reasoning, as she denies she has a mental illness and denies she needs medication, even though she has 8 prior MH cases and involuntary commitments.” Appellant's App. Vol. II, p. 10. This appeal followed.

Discussion and Decision

[13] M.M. claims the Center failed to present sufficient evidence to support the trial court's judgment. When reviewing the sufficiency of the evidence supporting an order of civil commitment, we consider only the probative evidence and reasonable inferences supporting it, without weighing evidence or assessing witness credibility. F.L. v. Cmty. Fairbanks Behav. Health, 245 N.E.3d 1033, 1035 (Ind. Ct. App. 2024), trans. denied. We will affirm if clear and convincing evidence supports the trial court's order. Id. The clear and convincing evidence standard “is defined as an intermediate standard of proof greater than a preponderance of the evidence and less than proof beyond a reasonable doubt.” Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034, 1038 (Ind. Ct. App. 2016).

[14] A petitioner in an involuntary commitment proceeding “is required to prove by clear and convincing evidence that ․ the individual is mentally ill and either dangerous or gravely disabled; and ․ detention or commitment of that individual is appropriate.” Ind. Code § 12-26-2-5(e) (2007). On appeal, M.M. does not dispute she is mentally ill. We focus on the question of grave disability.

[15] The General Assembly has defined “gravely disabled” as

a condition in which an individual, as a result of mental illness, is in danger of coming to harm because the individual:

(1) is unable to provide for that individual's food, clothing, shelter, or other essential human needs; or

(2) has a substantial impairment or an obvious deterioration of that individual's judgment, reasoning, or behavior that results in the individual's inability to function independently.

Ind. Code § 12-7-2-96 (1992).

[16] Because Indiana Code section 12-7-2-96 is written in the disjunctive, “a trial court's finding of grave disability survives if we find that there was sufficient evidence to prove either that the individual was unable to provide for [her] basic needs or that [her] judgment, reasoning, or behavior was so impaired or deteriorated that it resulted in [her] inability to function independently.” Commitment of B.J., 67 N.E.3d at 1039.

[17] On the issue of M.M.’s inability to function independently due to a deterioration in her judgment, reasoning, or behavior, the evidence demonstrates she denied having a chronic mental illness: (1) during her emergency commitment; and (2) while testifying at the evidentiary hearing. She has been diagnosed with schizo-affective disorder, an illness with psychotic and mood components that require medication. And when she arrived at the emergency department, she displayed manic and psychotic symptoms that continued to manifest throughout her emergency commitment.

[18] On a related topic, M.M. has denied the need for medications to treat her illness. Earlier in 2024, she quit taking medications from the Center on an outpatient basis. Upon being placed in the Center's psychiatry department on an emergency basis, M.M. refused to accept injectable medications, despite having supported them before. She accepted oral medications only after being at the Center for four days. M.M.’s symptoms improved after taking oral medications. Based on her claim to not need medication, the trial court could reasonably infer that M.M. would stop taking medications if permitted, causing a resurgence of her serious symptoms.

[19] Finally, the evidence shows M.M. was at risk of coming to harm based on the deterioration in her judgment or thinking. She gave several different explanations for how she sustained her head injuries, and her psychiatrist concluded the injuries were related to her untreated mental illness. In addition, M.M. was unhoused before arriving at the Center's emergency department, and her psychiatrist stated she had no plan for housing upon being discharged. Her psychiatrist did not think she could carry out activities of daily living without further treatment.

[20] M.M. points to other portions of her testimony in which she said she had sources of income and had rented an apartment. She also stated she intended to resume seeing a specific psychiatrist on an outpatient basis after being released from the Center, and if that doctor recommended that she take medication, she would comply even though she does not think she is mentally ill. The trial court was not obligated to credit M.M.’s testimony, and we will not reweigh the evidence. The Center provided sufficient evidence of M.M.’s grave disability to meet the clear and convincing evidence standard. See In re Commitment of C.P., 10 N.E.3d 1023, 1027 (Ind. Ct. App. 2014) (affirming trial court's determination of grave disability; patient denied mental illness or need for medicine despite displaying severe symptoms, and doctor stated patient's lack of insight and severe symptoms would not allow her to live independently), trans. denied.

Conclusion

[21] For the reasons stated above, we affirm the judgment of the trial court.

[22] Affirmed.

Baker, Senior Judge.

Chief Judge Altice and Judge Mathias concur. Altice, C.J., and Mathias, J., concur.