IN RE: the Civil Commitment of: B.C. (2025)

MEMORANDUM DECISION

[1] B.C., who has a history of bipolar disorder, expressed violent threats and suicide ideations upon her second mental health hospitalization in October 2025. The hospital petitioned for her involuntary civil commitment to ensure she received the treatment that she was refusing. The trial court granted that petition after finding B.C. met the statutory requirements for commitment because she was mentally ill and gravely disabled. She appeals, contending the evidence was insufficient to prove that she was gravely disabled. Finding clear and convincing evidence supports that finding, we affirm.¹

Facts

[2] In late October 2025, B.C. was admitted to Community Fairbanks Behavioral Health (Hospital) after having been hospitalized for four days earlier that month. At the time, B.C. was living and receiving substance abuse treatment at Avenues Recovery Residential (Avenues). Avenues staff had taken her to Hospital for the second time for evaluation of physical complaints (migraines and vaginal irregularities) and because she was exhibiting manic and aggressive behavior.

[3] At the time of her Hospital admission, B.C. exhibited disorganized thoughts, pressured speech, irritability, and paranoid thinking. She reported trying to perform “spells” by burning her hair and fingernails to help herself sleep. Tr. Vol. II, p. 9. She also expressed concern about contracting sexually transmitted diseases from other Avenues residents and threatened to “beat [those residents] up” if she did. Id. B.C., who reported a history of 10 suicide attempts, also expressed suicidal ideations. She declared that she wanted to starve herself to death and that she would kill herself if forced to return to Avenues.

[4] Dr. Sara Worsham, a psychiatry resident physician at Community Health Network working under attending physician supervision, diagnosed B.C. with “bipolar one disorder, current or most recent episode manic with psychotic features.” Id. at 10. B.C. denied her need for treatment and did not recognize that she was experiencing a manic episode.

[5] This lack of insight into her illness led B.C. to refuse to take medications that Dr. Worsham believed she needed. For instance, B.C. rejected Risperdal and Trileptal, the FDA-approved antipsychotics indicated for the acute manic phase of her type of bipolar disorder, because she believed she did not need the medications. B.C. merely agreed to take medications that Dr. Worsham believed were not indicated for acute mania and might aggravate manic symptoms.

[6] B.C. also threatened to harm herself and others. B.C., who reported having been jailed for dislocating someone's eye socket in 2014, stated that she wanted to hurt residents and staff at Avenues because they “irritate her.” Id. at 14. B.C. sometimes threatened that she would kill herself if forced to return to Avenues. At other times, she expressed her desire to return there. Whether Avenues would accept her back, given her behavioral difficulties with and threats to staff and residents, is unclear. B.C. also stated she could not return to her mother's home, leaving her post-hospitalization housing situation uncertain.

[7] B.C.’s thoughts were so disorganized and tangential that Dr. Worsham had “a really hard time understanding [B.C.’s] communication as well as her needs.” Id. at 14. When Dr. Worsham spoke to her, B.C. often interrupted and redirected the conversation, preventing the physician from discussing with B.C. her diagnosis or housing plans.

[8] Hospital petitioned for B.C.’s temporary involuntary civil commitment the day after her admission, and a hearing was held four days later. Immediately before the hearing, Dr. Worsham examined B.C. for the fourth time during that particular hospitalization. When Dr. Worsham informed B.C. that her bacterial vaginosis test was positive, B.C. stated that she “want[ed] to choke” the person at Avenues that she believed had transmitted the infection. Id. at 14.²

[9] Dr. Worsham testified that B.C.’s mental illness substantially impaired her judgment, reasoning, and behavior, affecting her ability to function independently. She identified as concerning behaviors B.C.’s persistent irritation and hyperverbal threatening statements. B.C.’s impaired judgment placed her and others at risk of harm, according to Dr. Worsham. According to the physician, individuals with bipolar disorder have suicide rates twenty to thirty times higher than the general population, with five to twenty percent completing suicide. Given B.C.’s reported history of more than ten suicide attempts and her recent suicidal statements, Dr. Worsham believed B.C.’s risk of self-harm was substantial.

[10] Dr. Worsham testified that, without commitment and medication stabilization, B.C. likely would not take her prescribed antipsychotics and her prognosis would be poor. With appropriate treatment, however, B.C.’s prognosis was very good, according to Dr. Worsham, because the medications would reduce her suicidal ideation and inclination to act out. The physician testified that a temporary commitment was the least restrictive treatment available and would allow time to engage B.C. in treatment, improve her symptoms, and help her gain insight into her mental illness.

[11] B.C. also testified at the hearing. She often interrupted her attorney, making it difficult for him to complete his questions. She moved rapidly between topics—discussing her mother's substance use, plans for various residential facilities, concerns about Vermillion County law enforcement, past relationships, her grandmother's inheritance, religious issues, and previous employers.

[12] B.C.’s testimony revealed the uncertainty about her housing plans to which Dr. Worsham had earlier testified. She stated she would never return to her mother's home and that she instead would go to another specific residential recovery center. But she acknowledged she had been “kicked out [of that facility] over buying Xanax.” Id. at 44. B.C. also testified that she planned to return to Avenues pursuant to a commitment she signed and that she might attend “next steps,” which she described as “like a bible cult” that she did not want to attend. Id. B.C. expressed frustration with some Avenues residents, describing them as young adults struggling with addiction who “think[ ] they're better than everybody.” Id. at 35.

[13] At one point, B.C. proclaimed: “I was criminally confined with Google Maps.” Id. at 40. She also testified that Dr. Worsham's sister works at Avenues and that “they look just alike.” Id. at 36. But Dr. Worsham denied having a sister.

[14] B.C. did not accept the diagnosis of bipolar disorder, stating Dr. Worsham could not “medicate a person's attitude, personality, or attitude (sic) just because they don't agree with her or like it.” Id. at 45. She described herself as having only “chronic depression” rather than bipolar disorder. Id. at 11, 38.

[15] Based on this evidence, the court found that B.C. exhibited “flight of ideas, irritability, pressured speech, and elevated mood” as well as disorganized thoughts—all symptoms of bipolar disorder as described by Dr. Worsham. Id. at 50. The court viewed B.C. as having “no insight into the debilitating effects of this mental illness,” elevating “her risk of suicide and physical conflict with the people around her.” Id. at 50. Noting B.C.’s description of feeling suicidal during her prior admission in October and that this was her second psychiatric hospitalization within thirty days, the court found that “the only safe place for [B.C.] is the safe confines of [Hospital].” Id.

[16] Finding that B.C. suffered from mental illness and was gravely disabled, the trial court ordered her commitment to Hospital for up to 90 days. The court also ordered B.C. to take all medications as prescribed, attend all clinic sessions as scheduled, maintain a current address and phone number with the court and Hospital, and refrain from harassing or assaulting family members or others and using alcohol or drugs other than those prescribed by a certified medical doctor. B.C. appeals.

Discussion and Decision

[17] B.C. argues that Hospital presented insufficient evidence to support her temporary involuntary civil commitment. When reviewing such a claim, 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 affirm if a reasonable trier of fact could have found the necessary elements proven by clear and convincing evidence. Id.

[18] To obtain an individual's involuntary civil commitment, Indiana Code § 12-26-2-5(e) (Involuntary Commitment Statute) requires the 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.” B.C. challenges only whether Hospital proved by clear and convincing evidence that she was gravely disabled. Finding the evidence sufficient on that issue, we affirm.

[19] For purposes of the Involuntary Commitment Statute, “gravely disabled” means:

[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 statute 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). The evidence introduced at the commitment hearing was sufficient to prove both statutory prongs.

A. Prong One: Inability to Provide for Essential Needs

[20] B.C. first argues that Hospital failed to prove that she could not provide for her essential human needs. She claims that Dr. Worsham testified that B.C. was able to meet her basic needs. But Dr. Worsham actually testified that B.C. was able to meet her basic needs except for housing. Tr. Vol. II, p. 12.

[21] B.C. also points out that the trial court ruled Dr. Worsham's testimony about B.C.’s ability to return to Avenues was admissible only for diagnosis and treatment purposes, not to prove B.C.’s grave disability. This means that Hospital presented no admissible evidence to rebut B.C.’s testimony that she could return to Avenues, according to B.C.

[22] But B.C. ignores her own testimony, on which the trial court could rely in finding her gravely disabled. B.C.’s testimony revealed profound uncertainty and confusion about her housing plans. She variously stated she would go to one of three different treatment centers. Yet she acknowledged she had been involuntarily removed from one of those centers previously and expressed hostility toward Avenues and its residents. She also likened the third facility to a “cult” and stated that she did not want to go there. Id. at 44.

[23] Thus, B.C.’s own testimony demonstrated that she had no clear, stable housing plan or option. The trial court could reasonably infer from B.C.’s contradictory and hostile statements that her ability to secure stable housing was compromised by her mental illness. In addition, B.C.’s threat to starve herself to death also suggests B.C.’s inability—that is, her apparent unwillingness—to provide herself with the basic necessity of food. Thus, clear and convincing evidence supports the trial court's finding that B.C. was gravely disabled because she could not provide for her basic need for food or shelter due to her mental illness. See J.D. v. Richard L. Roudebush Veterans Affs. Med. Ctr., 251 N.E.3d 1090, 1093-94 (Ind. Ct. App. 2025) (affirming trial court's ruling that patient was gravely disabled, in part, because he could not meet his housing, food and clothing needs).

B. Prong Two: Inability to Function Independently Due to Impaired Judgment, Reasoning, or Behavior

[24] The second prong of Indiana Code § 12-7-2-96 defining “gravely disabled” requires not only a “substantial impairment” or “obvious deterioration of ․ judgment, reasoning, or behavior” but also that this impairment or deterioration “results in the individual's inability to function independently.” (emphasis added). B.C. contends Hospital failed to prove her inability to function independently. She claims the evidence showed: (1) she sought medical treatment for legitimate health issues (migraines and her belief that she had contracted a sexually transmitted disease from another Avenues resident); and (2) she denied only that she was manic—not that she has a mental illness—and agreed to take some medications of her choosing.

[25] Although B.C. appears to concede that Hospital presented other evidence of her inability to function independently, she argues that this evidence did not meet the clear and convincing standard. She notes, for instance, that “unspecified verbal threats and potentially delusional thinking,” although characteristic of a person with mental illness, alone are insufficient to uphold an involuntary commitment. See generally K.F. v. St. Vincent Hosp. & Health Care Ctr., 909 N.E.2d 1063, 1067 (Ind. Ct. App. 2009) (finding evidence of grave disability insufficient when the patient merely made unusual decisions and displayed symptoms commonplace for her mental illness), disapproved on other grounds by T.K., 27 N.E.3d at 274; see also Addington v. Texas, 441 U.S. 418, 426-27 (1979) (ruling that the “loss of liberty [through a commitment] calls for a showing that the individual suffers from something more serious than is demonstrated by idiosyncratic behavior”).

[26] B.C. argues that even if she had been in denial of her mental illness and refused to take medication, such evidence alone is insufficient to justify her commitment. See generally T.K., 27 N.E.3d at 276 (ruling 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” (internal quotation omitted)).

[27] B.C. claims the trial court found she was gravely disabled only by contravening R.P. v. Optional Behav. MHS, 26 N.E.3d 1032, 1035 (Ind. Ct. App. 2015). In that case, this Court held that three factors must be considered in evaluating grave disability for purposes of Indiana Code § 12-7-2-96(2): “the gravity of the behavior leading to hospital admission, behavior in the hospital, and the relationship between problematic behaviors and the person's mental illness.” Id. (quoting In re Commitment of T.K., 993 N.E.2d 245, 248 (Ind. Ct. App. 2013)).

[28] B.C.’s argument is factually selective and misapprehends the applicable legal standard. The trial court's oral and written rulings show that it considered the three R.P. factors before finding B.C. to be gravely disabled under the second prong of Indiana Code § 12-7-2-96 and that the evidence amply supports the court's ultimate conclusion.

[29] In its oral ruling, the court noted that B.C. is “gravely disabled in her judgment and reasoning because she's not capable of perceiving the world around her correctly and responding to it correctly.” Tr. Vol. II, p. 50. The court then provided extensive examples of how this impairment manifested in B.C.’s inability to function: she could not conduct herself appropriately in court, could not answer her attorney's well-posed questions, brought up ideas about treatment not “based in reality,” and expressed willingness to engage in misconduct at a treatment facility. Id. at 50.

[30] In its written commitment order, the court elaborated on its grave disability finding:

[B.C.] is gravely disabled in her judgment and reasoning by bipolar disorder, including the delusion her psychiatrist's sister works at the home where [B.C.] lived. She is unable to control her manic symptoms, including flight of ideas, disorganized thought, irritability, and pressured speech and cannot make safe decisions. She has been hospitalized twice this month for mental health emergency (sic) but refuses medications and denies she suffers from a mental illness. [B.C.] has a long history of substance abuse and suicide attempts and said she wanted to die earlier this month.

App. Vol. II, p. 7.

[31] These rulings show that the court relied on more than just B.C.’s mental illness symptoms or her denial of mental illness in finding her gravely disabled. Instead, the court complied with R.P. by considering B.C.’s behavior that led to the hospital admission, her behavior in the hospital, and the relationship between her problematic behaviors and her mental illness. See R.P., 26 N.E.3d at 1035. The record amply supports the trial court's finding that B.C. is gravely disabled.

[32] For instance, the evidence showed that B.C. refused medications for acute mania (Risperdal and Trileptal) while insisting she could take medications contraindicated for her condition (Effexor and Lamictal). She made repeated threats to harm herself or others, both before and during her hospitalization and during the commitment hearing.

[33] Moreover, B.C.’s testimony revealed profound confusion about where she would live. Her contradictory statements—ranging from facilities she had been expelled from, to places she refused to go, to facilities she disparaged—demonstrated her inability to secure stable housing independently. B.C.’s inability to conduct herself properly in the courtroom was evident. She failed to answer her attorney's questions coherently, jumped between unrelated topics, and offered what the court viewed as “delusional” testimony. Tr. Vol. II, p. 50.

[34] Contrary to B.C.’s claim, this evidence shows her conduct was not just the display of “certain behaviors characteristic of a person with bipolar disorder” that was found insufficient to establish grave disability in K.F., 909 N.E.2d at 1067. Unlike the respondent in K.F., who could function independently with minor family assistance, B.C. demonstrated an inability to engage in basic communication, make safe decisions, or secure stable housing.

[35] B.C.’s argument that her decision to seek medical treatment for legitimate health concerns establishes her ability to function independently is also unavailing. This argument conflates one instance of appropriate behavior with the sustained ability to function independently. The grave disability statute does not require perfect dysfunction—it requires impairment that “results in the individual's inability to function independently.” Ind. Code § 12-7-2-96(2) (emphasis added).

[36] The evidence showed that while B.C. sought treatment for physical symptoms, her presentation was accompanied by severe psychiatric symptoms: disorganized thoughts, pressured speech, paranoid thinking, suicidal ideation, threats to harm others, and attempts to perform spells by burning her hair and fingernails. Indeed, Avenues staff brought her to the hospital not just for physical complaints but because she was exhibiting “manic and aggressive” behavior. Tr. Vol. II, p. 9.

[37] Moreover, B.C.’s response to her positive bacterial vaginosis test demonstrates her impaired judgment. Rather than focusing on gaining medical information about the diagnosis or various treatment options, she immediately threatened violence against the person she believed transmitted the infection. This response undermines B.C.’s argument that she can respond appropriately to health situations.

[38] This was, after all, B.C.’s second psychiatric hospitalization within thirty days, as the trial court noted. After a four-day hospitalization in early October, B.C. returned in crisis just thirteen days later. This pattern of rapid readmission confirms Dr. Worsham's testimony that B.C. cannot maintain stability without hospital-level support. The trial court could reasonably infer that B.C.’s inability to maintain stability between hospitalizations evidenced her inability to function independently.

[39] B.C.’s behavior on the day of the commitment hearing further buttresses the trial court's finding of grave disability. Dr. Worsham testified that when she examined B.C. on the morning of the commitment hearing, B.C. still exhibited disorganized thoughts, distractibility, and racing thoughts. More significantly, the trial court observed B.C. testify at the hearing. Her inability to conduct herself appropriately in court, her difficulty answering her attorney's questions, and her tangential and disorganized presentation all supported the trial court's judgment—that B.C. is gravely disabled because she has a substantial impairment or obvious deterioration of judgment, reasoning, or behavior that results in her inability to function independently.

Conclusion

[40] For these reasons, we find the record contains clear and convincing evidence that B.C. was gravely disabled. We therefore affirm B.C.’s commitment to Hospital's care for a period not to exceed 90 days.

[41] 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 because the standard appellate timeline often exceeds the typical duration of temporary mental health commitments. In re Marion Cnty. Expedited Mental Health Appeals Pilot Project, No. 24S-MS-190, Order p. 1 (Ind. July 16, 2024).

2.   Dr. Worsham testified that, although bacterial vaginosis may be caused by a sexually transmitted disease, other causes for the condition exist.

Weissmann, Judge.

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