IN RE: the Civil Commitment of J.A. (2025)

MEMORANDUM DECISION

[1] J.A. appeals the Marion Superior Court's order involuntarily committing him to the Sandra Eskenazi Mental Health Center (“the Hospital”) for a period not to exceed ninety days. J.A. argues that the trial court's findings that he is mentally ill and gravely disabled are not supported by clear and convincing evidence.

[2] We affirm.

Facts and Procedural History

[3] In February 2025, twenty-eight-year-old J.A. lived with his mother in Indianapolis. Although J.A. had been employed in the past, he had not worked since May 2024. J.A.’s mother reported that for several months J.A. expressed his beliefs that Ellen DeGeneres and Amazon were involved in a conspiracy to convince J.A. to commit suicide. J.A. also told his mother to kill herself and threatened his mother's friends. J.A. believed that his mother was poisoning him and that someone was smearing feces on items in their home.

[4] On February 17, at approximately 9:30 p.m., J.A.’s mother was washing dishes. J.A. approached her in the kitchen, yelled at her, and told her to confess that she was “part of this conspiracy ․” Tr. p. 6. J.A. grabbed the sponge from his mother's hand and threw it. He continued to yell at his mother, and then he swiped his arm across the counter, knocking items to the floor. He also pushed his mother on the shoulder. J.A.’s mother did not believe he was trying to injure her but that he was trying to “provoke [her] into fighting ․” Id. J.A. had never touched his mother in an angry manner prior to that incident.

[5] J.A.’s mother was concerned for his safety and that J.A.’s behavior was “escalating in a way that might be dangerous for” her. Id. J.A.’s mother was also concerned about J.A.’s suicidal thoughts and J.A.’s diet. J.A. refused to eat anything his mother prepared due to his belief that his mother was trying to poison him. Therefore, J.A. mostly ate “ramen and rice” or an occasional frozen meal. Id. at 7.

[6] J.A.’s mother called 911, but J.A. was respectful toward the officers and did not exhibit any aggressive behavior in their presence. Id. at 7. The officers recommended that J.A.’s mother leave the home for her own safety but did not remove J.A. from the home that evening.

[7] Although the record is unclear on specifics, the next day police removed J.A. from his mother's residence and took him to the Hospital. Thereafter, the Hospital filed an Application for Emergency Detention of J.A. The Application alleged that J.A. suffered from mental illness and was “dangerous to self, dangerous to others, or gravely disabled[.]” Appellant's App. Vol. 2, pp. 13-14. After J.A. was detained, Psychiatrist Dr. Kenneth Smith assumed care over J.A. and recommended temporary commitment of J.A. to the Hospital. The court held a hearing on the Hospital's Petition for Temporary Mental Health Commitment on February 27.

[8] At the hearing, Dr. Smith testified that J.A. suffers from delusional thoughts and expressed concern about J.A.’s “behavior leading to some signs of aggression.” Tr. p. 18. Dr. Smith also believed that “there is [a] possibility that [J.A.’s] delusions can lead to possibly greater acts of aggression that could lead to another individual or he himself being harmed.” Id. Dr. Smith explained that “[p]sychotic disorders that include delusions as a symptom usually worsen over time when they go untreated.” Id. Dr. Smith opined that without treatment, J.A. would experience increasing delusions, which would lead to “increasing aggressive behavior ․” Id. at 18-19.

[9] J.A. refused to take the antipsychotic medications that Dr. Smith ordered for him while he was admitted to the Hospital. J.A. told the doctor that “he is not interested in any treatment ․ because he doesn't feel that he has any mental health problems at all.” Id. at 19. Dr. Smith believed that J.A.’s delusional thoughts “are preventing him from being able to have a reliable judgment and reasoning due to impairment with being able to discern what is real and what is not.” Id. And Dr. Smith was not surprised that J.A. refuses to believe that he suffers from mental illness, specifically delusional disorder. Id.

[10] J.A. testified and denied suicidal thoughts or thoughts of hurting other people. Id. at 35. At the hearing, he expressed his continued belief that he had suffered an “irregular assault,” which he described as “if someone tries to harm you with the waste, essentially, if someone were to die from that, that would be potentially ․ murder.” Id. at 38. J.A. clarified that he was referring to some unidentified individual smearing feces on items in his home. Id.

[11] J.A. testified that if he were released from the Hospital, he believed he could obtain employment at Speedway and live with other family or friends. Id. at 32, 40. J.A. stated that he had not sought employment since after he was terminated from his prior employment in May 2024 because he was sick. Id. at 41. J.A. also stated he had a substantial sum of money in his savings account.

[12] The court concluded that J.A. suffers from delusional disorder, which “has rendered him gravely disabled in his judgment and reasoning because he wrongly perceives threats where there are none, especially from the people closest to him.” Id. at 45. The court issued an order temporarily committing J.A. to the Hospital for a period not to exceed ninety days.

[13] J.A. has filed this expedited appeal.

Discussion and Decision

[14] J.A. argues that the trial court's commitment order is not supported by clear and convincing evidence. An adult person may be civilly committed either voluntarily or involuntarily. Commitment of T.K. v. Dep't of Veterans Affs., 27 N.E.3d 271, 273 (Ind. 2015). “[T]he purpose of civil commitment proceedings is dual: to protect the public and to ensure the rights of the person whose liberty is at stake.” Id. “The liberty interest at stake in a civil commitment proceeding goes beyond a loss of one's physical freedom, and given the serious stigma and adverse social consequences that accompany such physical confinement, a proceeding for an involuntary civil commitment is subject to due process requirements.” Id. (citing Addington v. Texas, 441 U.S. 418, 425-26, 99 S. Ct. 1804, 1809 (1979)). “To satisfy the requirements of due process, the facts justifying an involuntary commitment must be shown ‘by clear and convincing evidence ․ [which] not only communicates the relative importance our legal system attaches to a decision ordering an involuntary commitment, but ․ also has the function of reducing the chance of inappropriate commitments.’ ” Id. (quoting Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448, 450 (Ind. Ct. App. 1991), trans. denied).

[15] When an appellate court reviews the sufficiency of the evidence supporting a civil commitment, the court considers only the probative evidence and reasonable inferences supporting it, without weighing evidence or assessing witness credibility. See id. We will affirm if clear and convincing evidence supports the trial court's judgment. Id. Clear and convincing evidence requires proof that the existence of a fact is “highly probable.” In re Commitment of C.N., 116 N.E.3d 544, 547 (Ind. Ct. App. 2019).

[16] To prevail on its request for a temporary civil commitment of J.A., the Hospital was required to prove that, J.A. was “mentally ill and either dangerous or gravely disabled” and that commitment of J.A. was appropriate. See Ind. Code § 12-26-2-5(e). Here, the trial court found that J.A. was mentally ill and gravely disabled but did not find that J.A. was dangerous. Tr. p. 45.

[17] J.A.’s argument that clear and convincing evidence does not support the trial court's finding that he is mentally ill is simply a request to reweigh the evidence and credibility of the witnesses, which is not our role. Indiana Code section 12-7-2-130 defines “mental illness” or “mentally ill” as: “a psychiatric disorder that: (A) substantially disturbs an individual's thinking, feeling, or behavior; and (B) impairs the individual's ability to function.”

[18] Both Dr. Smith's testimony and that of J.A. himself proved that J.A.’s delusional thoughts have substantially disrupted his thinking and behavior. Dr. Smith testified that J.A. suffers from delusional disorder. Tr. p. 19. J.A. believes his mother is trying to poison him and he was physically aggressive toward his mother when he confronted her with his delusional thinking on February 17. Because J.A. was aggressive with her, his mother will not allow him to return to her home unless he receives mental health treatment. J.A.’s delusions also impair his ability to function. J.A. will not eat food prepared by his mother. He also did not attempt to find employment after his previous employment was terminated. J.A. explained that he was sick because he is being assaulted by someone who is smearing feces on items in his home, and therefore, he could not find another job. Tr. pp. 38, 41. J.A.’s own testimony supports the trial court's finding that he is mentally ill.

[19] Next, J.A. argues that the Hospital did not present clear and convincing evidence that he is gravely disabled. Indiana Code section 12-7-2-96 defines “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.

The statute is written in the disjunctive, and therefore, the Hospital was only required to prove one of the two prongs by clear and convincing evidence. See A.S. v. Ind. Univ. Health Bloomington Hosp., 148 N.E.3d 1135, 1140 (Ind. Ct. App. 2020). In its brief, the Hospital focuses on the second prong. Appellee's Br. at 12.

[20] J.A. does not believe that he is mentally ill and he has refused Dr. Smith's recommended course of treatment. J.A.’s conduct and testimony establish that he will not be compliant with medication if not committed. Dr. Smith explained that “there is a possibility that [J.A.’s] delusions can lead to possibly greater acts of aggression that could lead to another individual or he himself being harmed.” Tr. p. 18. Dr. Smith explained that “[p]sychotic disorders that include delusions as a symptom usually worsen over time when they go untreated.” Id. Dr. Smith believed that without treatment, J.A.’s delusional thoughts would increase as would the likelihood that J.A. would engage in aggressive behavior. Id. at 18-19.

[21] J.A. also experienced delusional thoughts encouraging him to commit suicide. And his delusions resulted in the termination of his prior employment. J.A. did not seek new employment due to his delusional belief that he is sick because someone is smearing feces in his home. J.A.’s mother, who J.A. has lived with most of his life, will not allow him to reside in her home unless he participates in treatment for his mental illness. J.A. claimed he could live with other family members or friends and that he had substantial savings to support himself.¹ But it was within the trial court's discretion to determine whether J.A.’s testimony was credible.

[22] J.A. attempts to analogize his circumstances to those described in A.B. v. St. Vincent Hospital and Health Care Center, Inc., 240 N.E.3d 166, 172 (Ind. Ct. App. 2024), in which this court concluded that the Hospital failed to present clear and convincing evidence that the patient was gravely disabled. In that case, our court discussed the trial court's finding that A.B.’s judgment was impaired under Indiana Code section 12-7-2-96(2) because of her strange behavior during her detention at the stress center, her belief that she was infected with a parasite, her recent arrest for trespass, the fact that she opened the car door of a moving vehicle traveling on the interstate, and that A.B. refused to recognize her mental illness. Id. at 168, 170-71. Our court considered this evidence and explained:

[O]ur courts have echoed the caution called for by the United States Supreme Court in Addington v. Texas, 441 U.S. 418, 99 S.Ct. 1804, 60 L.Ed.2d 323 (1979). As we have noted, the Addington Court expressed concern that a decision ordering an involuntary commitment might be made on the basis of a few isolated instances of unusual conduct that occurred within a range of generally acceptable conduct. T.D. v. Eskenazi Health Midtown Cmty. Mental Health Ctr., 40 N.E.3d 507, 511 (Ind. Ct. App. 2015) (quoting In re Commitment of G.M., 743 N.E.2d 1148, 1151 (Ind. Ct. App. 2001)). The Addington Court opined that because everyone exhibits some abnormal conduct at one time or another, the loss of liberty that results from an involuntary commitment necessitates “ ‘a showing that the individual suffers from something more serious than is demonstrated by idiosyncratic behavior.’ ” Id. A.B. insisted in the car door incident she was simply discarding something from the car. Nevertheless, it appears to be an isolated incident like the arrest, about which we have very limited information. And, while A.B.’s other behaviors and beliefs were unusual, there was no evidence that they prevented her from functioning independently. The Stress Center's burden of proof required more than a showing that A.B. behaved abnormally or idiosyncratically.

Another circumstance that shaped the court's decision was A.B.’s failure to recognize her mental illness. However, our Supreme Court explicitly stated in Civil Commitment of T.K. that “denial of illness and refusal to medicate, standing alone, are insufficient to establish grave disability because they do not establish, by clear and convincing evidence, that such behavior ‘results in the individual's inability to function independently.’ ” 27 N.E.3d at 276 (quoting Ind. Code § 12-7-2-96(2)).

Id. at 171-72.

[23] Here, unlike A.B., J.A. did not live independently of his mother. His delusional thoughts were not isolated incidents but thoughts that he had been experiencing for many months. His delusion that his mother was poisoning him led to his threatening and aggressive behavior toward her the day before his detention and admission to the Hospital. And his delusion that some unidentified person was smearing feces on items in his home led him to believe that he was sick and could not seek employment. These delusional thoughts affect J.A.’s ability to function independently. J.A.’s refusal to recognize his mental illness and participate in treatment is additional evidence that he is gravely disabled. For all of these reasons, we conclude that the trial court's finding that J.A. was gravely disabled is supported by clear and convincing evidence.

Conclusion

[24] The trial court's order involuntarily committing J.A. to the Hospital for a period not to exceed ninety days is supported by clear and convincing evidence that J.A. suffers from mental illness and is gravely disabled. We therefore affirm the trial court's order.

[25] Affirmed.

FOOTNOTES

1.   No person had concerns about J.A.’s hygiene. J.A. was also eating regularly while detained in the Hospital. Mother had concerns about J.A.’s nutrition because he refused to eat the food she prepared. While this evidence supports J.A.’s claims that he is able to take care of his basic needs, this evidence does not persuade us that the trial court's finding that J.A. is gravely disabled under the second prong of Indiana Code section 12-7-2-96 is not supported by clear and convincing evidence.

Mathias, Judge.

Judges Tavitas and Weissmann concur. Tavitas, J., and Weissmann, J., concur.