IN RE: the CIVIL COMMITMENT OF R.P. (2026)

MEMORANDUM DECISION

Case Summary

[1] R.P. brings this appeal challenging his involuntary temporary commitment to 4C Health. R.P. claims the evidence is insufficient to show that he is gravely disabled. Concluding that clear and convincing evidence supports R.P.’s involuntary temporary commitment, we affirm.

Issue

[2] R.P. presents one issue, which we restate as whether the evidence is sufficient to support his involuntary temporary commitment.

Facts

[3] Fifty-four-year-old R.P. has been diagnosed with a schizoaffective disorder, bipolar type, has been hospitalized multiple times, and was receiving outpatient treatment at a 4C Health clinic. As part of his treatment, R.P. was prescribed a daily medication for schizophrenia.

[4] In March 2025, R.P. stopped taking his medication and stopped participating in outpatient services. In April, R.P. either quit or was terminated from his employment at Kroger, where he had worked for eight years. In June, R.P.’s landlord contacted 4C Health, R.P.’s emergency contact, because R.P. “looked as if he had lost weight” and was sleeping outside in the rain rather than in his apartment. Tr. Vol. II p. 11. The mobile crisis unit assessed R.P. and “at that time did not feel that he needed to be inpatient.” Id. at 7.

[5] On July 23, 2025, R.P. was found sleeping outside of the 4C Health Clinic. When approached by staff, R.P. said that he “came in to clear his name” from his diagnosis; “presented quite hyperverbal with pressured speech”;¹ and told Dr. Nizar El-Khalili that “he left his apartment because there was some illegal federal drugs being sold and manufactured there.” Id. R.P. was “endorsing delusional beliefs that ․ his public information was being disseminated and ․ 4C [Health] was ․ sabotaging him.” Id. at 11. R.P. agreed to be admitted as an inpatient.

[6] On the same day, 4C Health filed an application for emergency detention. 4C Health alleged that R.P. was mentally ill and gravely disabled. 4C Health contended that R.P. required involuntary detention because: “Client is having manic symptoms, including persecutory delusions and refuses medications, denying he has mental illness. His current symptoms have resulted in significant decline in function, loss of 8 yr job and becoming homeless.” Appellee's App. Vol. II p. 4. The trial court granted 4C Health's request for emergency detention.

[7] On July 29, 2025, 4C Health filed a petition for temporary involuntary commitment and alleged that R.P. had a mental illness and was gravely disabled. 4C Health alleged that R.P. had schizoaffective disorder and: “Prior to admission client was homeless and unable to meet daily living needs. Client has a history of medication noncompliance and untreated psychiatric disorder. Client exhibits severe psychosis and manic symptoms.” Appellant's App. Vol. II pp. 17, 18.

[8] A hearing was held on August 5, 2025. Dr. El-Khalili testified that, during R.P.’s hospitalization, his speech became less pressured, but he had no insight into his condition and performed “odd movements,” such as swimming on the floor, pushing his buttocks on the floor, and walking like a dog. Tr. Vol. II p. 7. Dr. El-Khalili testified that R.P. was gravely disabled and needed a long-acting injectable drug to prevent R.P. from repeating the “same pattern of him stopping the medication and then deteriorating and losing his job and residence because of the underlying illness that affects his judgment.” Id. at 8. R.P.’s prognosis without the medication was “poor.” Id. at 9. Nurse practitioner Amy Miller testified that R.P. had made inappropriate comments during his hospitalization and made “very hyper-sexual comments.” Id. at 14. Nurse Miller also testified that R.P. was gravely disabled.

[9] R.P. testified that he was “getting assessed a profile [he] feel[s] is incorrect” and claimed that, although he had been receiving medication for the last eight years, he had not been taking the medication. Id. at 23.

[10] After the hearing, the trial court issued an order granting 4C Health's petition for a temporary involuntary commitment of R.P. The trial court found that R.P. was “suffering from a psychiatric disorder, specifically: Schizoaffective disorder, bi-polar type” and that R.P. was gravely disabled. Appellant's App. Vol. II p. 22. R.P. now appeals. Following the initiation of his appeal, R.P. was discharged on August 14, 2025, and the trial court terminated the commitment on August 15, 2025.²

Discussion and Decision

[11] In Indiana, 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). In this case, 4C Health sought an involuntary temporary commitment of R.P. for a period not to exceed ninety days. See Ind. Code §§ 12-26-6-1 through -11.

[12] Our Supreme Court has held that “[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.” Commitment of T.K., 27 N.E.3d at 273. “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 (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).

[13] 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. 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).

[14] 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.

Ind. Code § 12-26-2-5(e). Here, R.P. does not challenge the trial court's determination that he is mentally ill or the appropriateness of the commitment; rather, R.P. challenges only the trial court's determination that he is gravely disabled.

[15] “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.

[16] R.P. argues that performing strange behaviors, refusing to admit to a diagnosis, and refusing to take medication do not mean the person is gravely disabled. Additionally, R.P. correctly states that temporary homelessness does not equate to grave disability. R.P.’s argument, however, overly simplifies the situation here. R.P. has a long history of hospitalizations for his mental illness; suddenly stopped participating in outpatient services; either quit or was terminated from his job of eight years; decided to sleep outside in the rain for an extended period of time rather than inside his apartment because he believed there was drug activity in his apartment building; appeared to have lost weight; slept outside the 4C Health clinic in an effort to have his diagnosis removed; has no insight into his mental illness; refused to take his medication; and exhibited strange movements and made inappropriate sexual comments during his hospitalization. Without medication, R.P.’s prognosis is poor.

[17] R.P.’s claims that he has not been taking his medication for eight years and that he is able to acquire new employment and housing without medication are merely requests that we reweigh the evidence and judge the credibility of the witnesses, which we cannot do. Under these circumstances, the clear and convincing evidence shows that R.P. has a substantial impairment in his judgment, reasoning, or behavior, which resulted in R.P.’s inability to function independently. The trial court did not err by concluding that R.P. is gravely disabled. See, e.g., T.G. v. Cmty. Health Network, 250 N.E.3d 490, 497 (Ind. Ct. App. 2025) (holding that the patient was gravely disabled because, “as a result of her mental illness, [she] was in danger of coming to harm because she was unable to provide herself with shelter”).

Conclusion

[18] 4C Health presented sufficient evidence to prove by clear and convincing evidence that, as a result of R.P.’s mental illness, he is gravely disabled. Accordingly, we affirm the trial court's judgment.

[19] Affirmed.

FOOTNOTES

1.   Dr. El-Khalili testified that pressured speech means “that the person is talking too fast, that they're not able to keep up with their thoughts” and “their speech become[s] very fast.” Tr. Vol. II p. 8.

2.   Although R.P. is no longer committed, we address R.P.’s arguments pursuant to J.F. v. St. Vincent Hosp. & Health Care Ctr., Inc., 256 N.E.3d 1260, 1263 (Ind. 2025), which held that a temporary commitment “order's expiration does not moot a timely appeal unless the appellee establishes the absence of any collateral consequences.” 4C Health does not argue that this case is moot.

Tavitas, Chief Judge.

Weissmann, J., and Foley, J., concur