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

MEMORANDUM DECISION

[1] L.J. appeals his involuntary temporary commitment to Community Fairbanks Behavioral Health (“Community” or “the hospital”) following a hearing in the Marion Superior Court. L.J. presents a single issue for our review, namely, whether the hospital presented sufficient evidence to prove that he is dangerous and gravely disabled.

[2] We affirm.

Facts and Procedural History

[3] In early May 2025, L.J. was living with his mom, K.J., and his dad ¹ in Indianapolis. L.J. had a recent history of being “agitated and erratic” and had struggled, without success, to make friends. Tr. p. 8. On the night of May 6, K.J. found a butcher's knife lying on a pillow on her bed. K.J. asked L.J. about the knife, and he “made comments that [she and his dad] were going to have to do a better job about being more subtle ․ [about] doing things with the knife that upset him, like where [they] placed it or how it was in the knife block or something.” Id. at 6.

[4] Then, early in the morning of May 7, L.J.

burst[ ] in[to] [his parents’ bed]room and turn[ed] the light on and [told them] to get up. He [had a] very, very angry tone and he [threw] a roll of duct tape on the bed and [told them] to duct tape [them]selves up. He had a knife and he wasn't kidding and [was] yelling and he then put[ ] his phone on the top of the dresser and play[ed] some really loud ․ heavy metal type music. And then he[ told them] he[ was] not kidding around[,] and [his dad] did not want to put the duct tape on, said he wouldn't. And then he [got] in his face with the knife and then he [took] his arm and clear[ed] everything off the nightstand, the lamps and pictures and [sat] down and crosse[d] his legs and [sat] and he[ had] a marijuana cigar type thing. He's smoking and flicking ashes and kind of in rhythm with the music and moving around and telling [them] to get ready[ and that it was] going to be a very long day.

Id. L.J. told his parents that they were going to go to a local car dealership to possibly kill the owner/manager there. And then L.J. played “softer” music and began to cry. Id. at 7. L.J. expressed sadness that he did not have any friends, and his dad offered to hug him, but he rejected a hug. L.J. was unable to get his parents restrained with duct tape, but he did eventually force them into a car.

[5] L.J. told his parents that they were going to drive to a nearby abandoned house and burn it down. L.J. had placed a gasoline container in the trunk of his car. When they arrived at the abandoned house, L.J.’s father begged him not to set it on fire. L.J. “tapped on the building,” which had some kind of metal siding, and then L.J. walked away. Id. at 8. L.J. told his parents that he was going to go downtown to “see what the big guy had for him.” Id. L.J.’s parents called law enforcement, and L.J. was eventually transported to Community that same day, where he was admitted.

[6] One day after his admission to the hospital, Community filed an application for emergency detention and alleged that

[L.J.] presents with Agitation and behavioral issues and threatening parents with a knife and threatening to burn the building and mood instability and paranoia. Collateral history obtained from [L.J.]’s outpatient psychiatrist and [from L.J. shows that he] has been delusional and paranoid and [there have been] homicidal concerns. [L.J.] is refusing to take prescribed psychotropic medications.

Appellant's App. Vol. 2, p. 7. That application was granted.

[7] L.J. was diagnosed with “bipolar one disorder manic with psychotic features.” Tr. p. 23. Community sought a temporary commitment order. At the ensuing hearing, Dr. Kanwaldeep Sidhu, a psychiatrist, testified that L.J. refused to answer any of his questions but that he had had trouble sleeping in the hospital. L.J. had refused to take mood stabilizing medications. Dr. Sidhu described L.J. as “guarded and suspicious.” Id. at 25. Dr. Sidhu stated that,

in [L.J.’s] refusal to answer even basic questions, we can't really help him. If he's had these incidents, he's landed in legal trouble and has had falling out with parents, has lost jobs and has been into trouble at school and a lot of times ․ , some of the mental illnesses, especially the mania, it has to affect your functioning. But it has, I think we can help him restore his functioning by giving proper treatment and with medication psychotherapy. But again, he has acknowledged a lot of the stuff that has happened in the past.

Id. Based on K.J.’s description of events that led to L.J.’s hospitalization, Dr. Sidhu said, “[i]t appears that he had psycho mood agitation and then aggression, elevated mood, disjointed speech, distractibility and delusional thinking.” Id. at 27.

[8] When he was asked whether L.J. presents a risk of harm to himself or others, Dr. Sidhu replied: “Yeah, I think it's based on the history. He does present a risk of harm especially to others and it's mainly the others. He hasn't expressed concerns about suicidal thinking, but people who have mania or episodes [have] a high risk of coming to self-harm as well.” Id. at 28. When asked whether L.J. was able to function independently in society, Dr. Sidhu stated:

Well, the functioning depends on—it's relative. So I don't think he can maintain relationships or [a] place of residence with the parents anymore. He hasn't been able to [maintain] jobs in the past because of his behaviors and [he hasn't been able to] do well in school. And he does tell me that he would go to a [shelter] if he leaves the hospital, but besides that, I don't think he can function well without help from other people.

Id. Dr. Sidhu also testified that L.J.’s prognosis was good with treatment but “very poor” without treatment. Id. at 29. L.J. did not testify at the hearing.

[9] At the conclusion of the hearing, the trial court concluded that L.J. was dangerous to others and gravely disabled, and the court ordered his temporary commitment. Specifically, the trial court found and concluded as follows:

[L.J.] is gravely disabled in his judgment and reasoning by the delusions of his bi-polar 1 disorder. He attacked his parents in their bedroom, and his psychiatrist says his aggressive and dangerous behavior is likely to continue to escalate if left untreated. He refuses to answer even basic questions from his psychiatrist because of his paranoia. His marijuana use is likely to reduce the effectiveness of the mental health medications that are necessary for him to make safe decisions. His judgment and reasoning are so grossly impaired that he will not cooperate in treatment for his long-standing mental health diagnosis, and he attacked the people who housed, care for, and love him, wrongly believing them to be part of a conspiracy involving the Vice Lords gang․

Appellant's App. Vol. 2, p. 28. This expedited appeal ensued.

Discussion and Decision

[10] L.J. contends that Community did not present sufficient evidence to show that he was either dangerous or gravely disabled to justify his temporary commitment. When reviewing the sufficiency of the evidence supporting a civil commitment, we consider only the probative evidence and reasonable inferences supporting it, without weighing evidence or assessing witness credibility. Civ. Commitment of T.K. v. Dep't of Veterans Affairs, 27 N.E.3d 271, 273 (Ind. 2015). 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.” Matter of Commitment of C.N., 116 N.E.3d 544, 547 (Ind. Ct. App. 2019).

[11] Indiana Code section 12-26-2-5(e) provides that a petitioner for a temporary commitment must prove by clear and convincing evidence that (1) an individual is mentally ill and either dangerous or gravely disabled and (2) detention or commitment of that individual is appropriate. Dangerous is defined as “a condition in which an individual[,] as a result of mental illness, presents a substantial risk that the individual will harm the individual or others.” I.C. § 12-7-2-53. An individual is “gravely disabled” when he has

a condition in which [the] 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.

I.C. § 12-7-2-96.

[12] On appeal, L.J. does not dispute that he is mentally ill. But he maintains that he is neither dangerous nor gravely disabled. While the statute is written in the disjunctive and Community need only prove one of those two elements, we address L.J.’s arguments on both.

The clear and convincing evidence supports the trial court's conclusion that L.J. is dangerous.

[13] L.J. argues that the incident with his parents, which occurred two weeks prior to the commitment hearing, could not support a determination that he was currently dangerous, as the statute requires. He also argues that Dr. Sidhu testified about the dangers posed by people with bipolar disorder, generally, and did not explain a specific risk of danger that L.J. presented to himself or others. We do not agree.

[14] L.J.’s argument amounts to a request that we reweigh the evidence. Dr. Sidhu testified that L.J. refused to talk to him about his mental illness, which certainly stymied Dr. Sidhu's assessment of him. But Dr. Sidhu testified that, “based on the history,” L.J. “does present a risk of harm especially to others” and that people with mania have a “high risk of coming to self-harm as well.” Tr. p. 28. And Dr. Sidhu agreed with the trial court's statement that, “if [L.J.’s mental illness were] left untreated,” Dr. Sidhu anticipated that “the symptoms [would] worsen over time․” Tr. p. 40. L.J. was refusing to take prescribed medications to treat his mental illness. And the trial court found that, “at this moment[, L.J.] is dangerous to others because he does not have the ability or willingness to engage in the treatment that would forestall those violent and threatening behaviors recurring.” Id. at 49.

[15] The evidence, taken as a whole, supports the trial court's conclusion that L.J. is dangerous. See, e.g., A.S. v. Cmty. Fairbanks Behav. Health, ___ N.E.3d ___, No. 25A-MH-804, 2025 WL 1319075, at *4 (Ind. Ct. App. May 7, 2025) (holding that the “record, as a whole,” showed that A.S. was dangerous to himself despite the fact that his suicidal ideations occurred prior to admission and “did not repeat” during hospitalization).

The clear and convincing evidence shows that L.J. is gravely disabled.

[16] L.J. also argues that there is no evidence that he is gravely disabled. But, again, L.J.’s argument amounts to a request that we reweigh the evidence, which we will not do on appeal.

[17] K.J. testified that L.J. is not welcome to return to live at his parents’ home after his release from the hospital. She testified that L.J. “lived in his car [for] most of the winter” and has previously stayed at a homeless shelter. Tr. p. 16. K.J. also testified that L.J. cannot maintain stable employment and has “had issues” at community college. Id. at 10. Dr. Sidhu testified that L.J. cannot “function well without help from other people.” Id. at 28.

[18] In addition, Dr. Sidhu's testimony showed that L.J. has a substantial impairment or an obvious deterioration of his judgment, reasoning, or behavior. L.J. will not even discuss his diagnosis and refuses prescribed medication. Dr. Sidhu testified that L.J.’s history of instability at home, work, and school shows that his mental illness is affecting his ability to function. Id. at 25. Dr. Sidhu testified further that, with “proper treatment” and medication, L.J.’s functioning could be restored. Id. Thus, Community presented sufficient evidence to show that L.J. is gravely disabled.

[19] For all these reasons, the trial court did not err when it ordered L.J.’s temporary commitment.

[20] Affirmed.

FOOTNOTES

1.   The record does not reveal what L.J.’s father's name is.

Mathias, Judge.

Judges Brown and Foley concur. Brown, J., and Foley, J., concur.