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

MEMORANDUM DECISION

[1] J.G. appeals his temporary involuntary civil commitment, challenging the sufficiency of the evidence to prove he was mentally ill and gravely disabled and that his commitment was appropriate. We find clear and convincing evidence to prove each of these elements and, therefore, affirm.¹

Facts

[2] J.G. is a 58-year-old musician who lives in the U.S. Virgin Islands. He has suffered from hypomanic episodes since at least 2017, but in December 2024, he stopped taking his prescribed mood-stabilizing medication. J.G. still uses recreational drugs, however, including marijuana and psychedelic mushrooms.

[3] On May 31, 2025, J.G. had a manic episode while visiting his mother (Mother) in Indianapolis. Mother took J.G. to Community Fairbanks Behavioral Health (the Hospital), where he presented with “confusion, altered mental status, disorganized thinking, [and] disorganized behavior.” App. Vol. II, p. 8. J.G. was admitted to the Hospital under a 48-hour hold, during which time he displayed “[a]gitation, aggression, paranoia, delusional thinking, confusion, [and] poor insight and judgment.” Id. Though J.G. tested positive for marijuana and cocaine upon admission, these drugs were eventually ruled out as the cause of his symptoms.

[4] On June 3, 2025, the Hospital filed an application for J.G.’s emergency detention, which the trial court granted. While detained, J.G. was examined multiple times by psychiatrist Kanwaldeep Sidhu, M.D. According to Dr. Sidhu, J.G. showed some insight into his mental health early in his hospitalization, but that insight soon evaporated. J.G. started to oppose his doctors’ treatment plan, became “very suspicious” about their intentions, and expressed feelings that they were “against him.” Id. at 10.

[5] J.G. also exhibited mania, grandiose thinking, and grandiose delusions during Dr. Sidhu's examinations. One of J.G.’s grandiose ideas was to start a “co-op” or “cooperative” in the Virgin Islands with several billionaires he claimed to know there. Id. at 22, 28. According to Dr. Sidhu, “[J.G.] talked about giving people ideas ․ and helping people start multiple restaurants.” Id. at 22. But he did not talk about this in a “logical way,” which indicated to Dr. Sidhu that J.G. had no knowledge of the restaurant industry. Id. Still, J.G. proclaimed the cooperative would “help people and change the world.” Id.

[6] Dr. Sidhu ultimately diagnosed J.G. with “unspecified schizophrenia spectrum disorder.”² Tr. p. 9. To treat this psychiatric illness, Dr. Sidhu prescribed J.G. antipsychotic and mood stabilizing medications. He also prescribed medication to treat J.G.’s high blood pressure. J.G. took these medications selectively and inconsistently for a few days. But on June 8, 2025, he began refusing to take any medication at all. According to Dr. Sidhu, J.G. indicated that he preferred to treat his symptoms with recreational drugs instead and stated that “he just needs marijuana and THC and mushrooms.” Id. at 11. J.G. also disclosed to Dr. Sidhu that he had used ketamine in the past and planned to continue using it in the future.

[7] J.G. was unable to provide Dr. Sidhu with much insight into his personal finances and could not articulate how he would provide for his basic needs upon discharge from the hospital. Though J.G. spoke about having a house in the Virgin Islands, he was guarded in doing so. And he ultimately told Dr. Sidhu that he would do “something” but did not want to reveal his plans. Id. at 23. Therefore, on June 9, 2025, the Hospital petitioned for J.G.’s temporary involuntary civil commitment.

Dr. Sidhu's Testimony

[8] At the civil commitment hearing on June 16, 2025, Dr. Sidhu testified that J.G.’s blood pressure readings had been in the “red range” every day of his hospitalization, which was “concerning.” Id. at 20. Though J.G. had taken his blood pressure medication that morning, his reading of 149/92 was still high. And when J.G. was refusing his blood pressure medication, his readings went as high as 152/107.

[9] On the issue of J.G.’s mental illness, Dr. Sidhu testified that he believes J.G.’s ability to care for himself has declined because of his symptoms and that he is, at best, “poor functioning.” Id. at 12. According to Dr. Sidhu, unspecified schizophrenia spectrum disorder causes “a lot of confusion and delusions and altered thinking, altered perceptions of reality and that can be disabling for anyone.” Id. at 13. He described J.G. as “confused about his surroundings” and stated that he “incorrectly perceives the world around him.” Id. at 27, 29. Dr. Sidhu also that explained people with paranoia or grandiose ideas commonly “respond inappropriately” to the world around them. Id. at 30.

[10] Dr. Sidhu further explained that one of the “prominent symptoms” of people with mania is “they either can't manage their money well or they give out the money randomly to people. Id. at 29. More generally, Dr. Sidhu testified that people with mania think they can help others and do so at the expense of their own wellbeing. Dr. Sidhu did not believe J.G. had the ability to manage his money in an organized manner due to his “mania and psychosis.” Id. at 24. And though Dr. Sidhu had never seen J.G. handle money, he explained that J.G. “can't really engage in a good conversation,” which would make a complex task like managing money “pretty hard.” Id.

[11] Additionally, Dr. Sidhu testified that J.G.’s suspiciousness, delusions, and grandiose ideas are evidence that he will not make safe decisions if discharged from the Hospital without treatment. Dr. Sidhu testified that J.G. cannot be relied upon to take his medications without hospital supervision or to follow up with his care and treatment if a commitment were not granted. Tr. pp. 14, 15. Dr. Sidhu also explained that marijuana, mushrooms, cocaine, and ketamine are “contraindicated” as medications for people with J.G.’s mental illness. Id. at 31. And according to Dr. Sidhu, J.G.’s prescribed medications would not be effective with the continued use of recreational drugs, especially mushrooms and cocaine. Dr. Sidhu emphasized that those drugs can make a person more psychotic and more manic—“it's like putting fuel on fire.” Id. at 30.

[12] Dr. Sidhu ultimately recommended that J.G. be temporarily committed to the Hospital. He explained that a temporarily commitment would allow more time to engage J.G. in treatment, including medication and psychotherapy, which in turn would improve his symptoms and help him gain insight into his mental illness. According to Dr. Sidhu, J.G. did not yet have the insight to seek treatment outside a hospital setting.

[13] Dr. Sidhu opined that J.G. would likely be hospitalized less than a week. Once stable enough to leave the hospital, J.G. would be referred to an outpatient mental health center for additional services for the remainder of the commitment period. Dr. Sidhu added that the Hospital would first look to J.G.’s mother to house J.G. during this time. And if that was not an option, they would look into boarding homes or shelters.

J.G.’s Testimony

[14] J.G. also testified at the civil commitment hearing. He denied having manic episodes or mental illness, and he claimed he took Mother to the Hospital because she—not he—was having a mental health crisis. Once they arrived, J.G. claimed, he voluntarily admitted himself to the Hospital simply because Mother asked him to. According to J.G., his involuntary detention thereafter is what caused him not to trust Dr. Sidhu and the other members of the Hospital treatment team. J.G. indicated that he would take medications and abstain from using recreational drugs only if his doctor in the Virgin Islands advised him to. He also advised that, if a commitment was not ordered, he planned to stay with his mother for a few days and then return to the Virgin Islands.

[15] On this issue of starting a cooperative, J.G. clarified that “the idea is to start a not-for-profit, to help people start cooperatives.” Id. at 45. He then elaborated:

The not-for-profit is a whole different thing than the cooperatives. The cooperatives are going to be brought to us by people who want to start up. And we're not going to give them huge amounts of money. We're going to grant them, but we're going to have guidelines that they're going to have to follow. Having a pay it forward board so people who can't afford the service that they're providing and they're going to have to donate money to other not-for-profits or back to the not-for-profit that we're starting. There's guidelines as far as how they're going to split the money, but everybody's going to be profit sharing, they're all going to be owners. All their ideas are going to matter. So people are going to give 100% into their venture because they're not going to feel like they're getting screwed over.

Tr. p. 46.

[16] J.G. admitted that he has no not-for-profit experience, but he identified three alleged billionaires in the Virgin Islands that he indicated were helping with the venture. He also testified: “I believe that I get messages from God, but I'm not religious. I'm on a spiritual journey.” Id. at 45. He then explained that a message from God spawned the idea to start the not-for-profit.

[17] At the close of evidence, the trial court found that J.G. was mentally ill and gravely disabled and that his involuntary commitment was appropriate. The court therefore ordered J.G.’s commitment to the Hospital for a period not to exceed 90 days. J.G. appeals.

Discussion and Decision

[18] J.G. argues that the Hospital presented insufficient evidence to support his temporary involuntary civil commitment. When reviewing the sufficiency of the evidence to support an involuntary civil commitment, we neither reweigh the evidence nor judge the credibility of witnesses. Civ. Commitment of T.K. v. Dep't of Veterans Affs., 27 N.E.3d 271, 273 (Ind. 2015). Instead, we consider the evidence and reasonable inferences most favorable to the judgment, and we will affirm if a reasonable trier of fact could have found the necessary elements proven by clear and convincing evidence. Id.

[19] To obtain an individual's involuntary civil commitment, Indiana Code § 12-26-2-5(e) (Involuntary Commitment Statute) requires a petitioner “to prove by clear and convincing evidence that: (1) the individual is mentally ill and either dangerous or gravely disabled; and (2) detention or commitment of that individual is appropriate.” J.G. challenges the sufficiency of the evidence to prove each of these elements. We find clear and convincing evidence of them all and affirm.

I. Mental Illness

[20] We begin by reviewing the evidence of J.G.’s mental illness. For purposes of the Involuntary Commitment Statute, “mental illness” is defined to mean “a psychiatric disorder that: (A) substantially disturbs an individual's thinking, feeling, or behavior; and (B) impairs the individual's ability to function.” Ind. Code § 12-7-2-130(1).

[21] At the civil commitment hearing, Dr. Sidhu explained J.G.’s diagnosis of unspecified schizophrenia spectrum disorder as follows:

[J.G.] continues to have paranoid thinking, paranoid delusions[,] feels people are against him. He has grandiose thinking, grandiose delusions, including ideas that he's going to start some cooperatives with a couple of billionaires that will change the world. And he still has a lot of irritability, agitation, [and] distractibility, and if you have them for a period of time, that's a diagnosis of schizophrenia spectrum.

Id. at 10.

[22] From this testimony, the trial court could reasonably conclude that J.G. had a psychiatric disorder that substantially disturbed his thinking and impaired his ability to function. See C.J. v. Health & Hosp. Corp. of Marion Cnty., 842 N.E.2d 407, 410 (Ind. Ct. App. 2006) (finding sufficient evidence of mental illness where doctor testified that committee “suffer[ed] from substance-induced psychosis” causing “grandiose and paranoid delusions, as well as disorganized thought processes and behavior”).

[23] J.G. claims Dr. Sidhu's testimony was insufficient to prove J.G.’s mental illness because it did not establish that J.G.’s paranoia was not, as J.G. testified, a product of his involuntary detention by Hospital. J.G. also claims Dr. Sidhu's testimony did not establish that his purported grandiose delusions were either untrue or anything more than puffery. These claims are merely an invitation for this Court to reweigh the evidence, which is not our role. See T.K., 27 N.E.3d at 273. Because the record contains clear and convincing evidence that J.G. was mentally ill, J.G.’s sufficiency challenge fails as to this element.

II. Grave Disability

[24] We next review the evidence of J.G.’s grave disability. For purposes of the Involuntary Commitment Statute, “gravely disabled” is defined to mean:

[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. Because this definition is written in the disjunctive, a petitioner need only prove that the respondent “was unable to provide for his basic needs or that his judgment, reasoning, or behavior was so impaired or deteriorated that it resulted in his inability to function independently.” In re Commitment of D.S., 109 N.E.3d 1056, 1060 (Ind. Ct. App. 2018)

[25] At the civil commitment hearing, Dr. Sidhu testified that, because of his mental illness, J.G. is “confused about his surroundings” and “incorrectly perceives the world around him.” Tr. pp. 27, 29. Dr. Sidhu also testified that one of the “prominent symptoms” of people in a manic state is they cannot manage their money and try to help random people financially to their own detriment. Id. at 29. J.G. was unable to provide Dr. Sidhu with much insight into his personal finances. But Dr. Sidhu did not believe J.G. had the ability to manage his own money due to his mania, psychosis, and resulting inability to “really engage in a good conversation.” Id. at 24.

[26] Additionally, a trial court could reasonably infer from the evidence of J.G.’s grandiose idea that he would mismanage his money without treatment. The record shows that J.G. wanted to “change the world” by creating a not-for-profit that helped other people start cooperatives. Although J.G. is not religious, he testified that this idea came to him in a message from God. And he vaguely explained the concept as he and three alleged billionaires granting people money with guidelines that they will either pay it forward or pay it back.

[27] Dr. Sidhu further testified that J.G.’s suspiciousness, delusions, and grandiose ideas are evidence that he will not make safe decisions if discharged from the Hospital without treatment. And this conclusion is supported by J.G.’s refusal to take prescribed antipsychotic and mood-stabilizing medications while also expressing desire to continue using recreational drugs that are known to exacerbate the symptoms of his mental illness. J.G.’s consistently high blood pressure and refusal to take prescribed blood pressure until the morning of the commitment hearing were also concerning to Dr. Sidhu.

[28] From this evidence, the trial court could reasonably infer that J.G. was in “danger of coming to harm” because of his mental illness. Ind. Code § 12-7-2-96. J.G. claims otherwise because our Supreme Court has ruled 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.” T.K., 27 N.E.3d at 276 (quotation omitted). But the hospital presented more than J.G.’s denial of illness and refusal to medicate to establish this element.

[29] Because the record contains clear and convincing evidence that J.G. was gravely disabled, J.G.’s sufficiency challenge fails as to this element as well.

III. Appropriateness of Commitment

[30] Finally, we review whether J.G.’s commitment was appropriate. A person who is involuntarily committed has the right to receive mental health services that are “appropriate to the patient's needs” and “designed to afford a reasonable opportunity to improve the patient's condition.” Ind. Code § 12-27-2-1(1). But whether a particular commitment is appropriate is fact-sensitive inquiry.” R.P. v. Optional Behav. MHS, 26 N.E.3d 1032, 1037 (Ind. Ct. App. 2015).

[31] At the civil commitment hearing, Dr. Sidhu testified that J.G. cannot be relied upon to take his medications without hospital supervision or to follow up with his treatment if a commitment were not granted. The evidence also indicated that J.G. intends to self-medicate with recreational drugs if he were discharged without a commitment, which could exacerbate his symptoms. Dr. Sidhu explained that a temporary commitment would allow J.G. to improve his symptoms and gain the insight into his mental illness so that he can then pursue continued treatment on his own. This testimony is sufficient to prove that J.G.’s involuntary commitment was appropriate. See In re Involuntary Commitment of A.M., 959 N.E.2d 832, 836 (Ind. Ct. App. 2011) (finding commitment appropriate where doctor testified that committee “would not do well in a less restrictive environment and needed continued hospitalization”).

[32] J.G. claims Dr. Sidhu's testimony is insufficient because the plan for J.G.’s outpatient treatment is impractical and underdeveloped. He points to Dr. Sidhu's testimony that J.G. would likely be hospitalized for less than a week and then be required to find housing in Indianapolis while he completes outpatient mental health services during the remainder of the commitment period. But Dr. Sidhu testified that J.G.’s mother may be able to house J.G. during this time, and J.G.’s testimony that he planned to stay with his mother for a few days upon discharge indicates that this is a viable option. If not, Dr. Sidhu also testified that boarding homes or shelters may be options.

[33] J.G.’s claims are, again, an impermissible request for us to reweigh the evidence. See T.K., 27 N.E.3d at 273. Because the record contains clear and convincing evidence that J.G.’s involuntary commitment was appropriate, J.G.’s sufficiency challenge also fails as to this element.

Conclusion

[34] For all these reasons, we affirm J.G.’s involuntarily commitment to the Hospital for a period not to exceed 90 days.

affirmed

FOOTNOTES

1.   This expedited appeal is part of the two-year Marion County Expedited Mental Health Appeals Pilot Project that the Indiana Supreme Court created to avert “[t]he typical duration of temporary mental health commitments often exceed[ing] the standard appellate timeline.” In re Marion Cnty. Expedited Mental Health Appeals Pilot Project, No. 24S-MS-190, Order p. 1 (Ind. July 16, 2024).

2.   Dr. Sidhu opined that, with further examination of J.G. and more information on his medical history, J.G.’s diagnosis would “likely” be refined to “bipolar one disorder manic with psychotic features.” Tr. p. 9.

Weissmann, Judge.

Mathias, J., and Foley, J., concur.