IN RE: the Civil Commitment of A.N. (2026)

MEMORANDUM DECISION

Statement of the Case

[1] A.N. is forty years old and has struggled with mental illness for over a decade. She has previously been the subject of orders of involuntary commitment for both outpatient and inpatient treatment. In the current case, A.N. appeals from the trial court's order of regular commitment, which requires her to receive outpatient care from Community Fairbanks Behavioral Health (“Fairbanks”). A.N. argues that the trial court used an incorrect legal standard and that there is insufficient evidence to support the judgment. Concluding that A.N. has failed to demonstrate error, we affirm.

Facts and Procedural History

[2] A.N. has a history of mental health challenges dating back to at least 2012, after the birth of her children. She has been the subject of six prior involuntary civil commitment cases, including cases in February, April, and November 2016, April 2020, November 2021, and February 2023.¹ Medical care providers have diagnosed her with schizoaffective disorder.

[3] A.N. lives in a house that her parents purchased for her and receives disability payments. She has a driver's license and owns a car.

[4] A.N. has a long history of refusing or resisting prescribed medications for mental illness, as well as skipping appointments with mental health providers. A.N. told her mother that she “hates” taking her medication because she “doesn't like how it makes her feel.” Tr. Vol. II, p. 16. She claimed the medication caused her to gain weight and feel lethargic and nauseous.

[5] When A.N. is not taking her medications or is less than fully compliant with the schedule, she becomes more erratic in communicating with her family and is prone to angry “outbursts.” Id. at 27. She also fails to manage her personal hygiene. Specifically, A.N. stops bathing and might not change her clothes for up to a week. She also stops cleaning her house.

[6] A.N.’s parents take care of her children during periods when she is not taking her medication. As of the date of the evidentiary hearing in this case, she was not allowed to have them at her home overnight or drive alone with them. A.N. told her mother that once her children graduate from high school, she will refuse to continue “taking anything.” Id. at 18.

[7] Dr. Gabriel Martinez, a psychiatrist at Fairbanks, has treated A.N. since April 2022. Dr. Martinez has noted that when A.N. is not taking medication, she displays delusions of grandeur and persecution, has disorganized behaviors and intrusive thoughts, and fails to manage her personal hygiene. Her disorganized behavior includes sending disjointed messages to Dr. Martinez and his team via an online patient portal. The messages consisted of screen shots of maps, emojis, and videos, all of which appear to be random and make no sense.

[8] According to Dr. Martinez, A.N.’s most consistent symptom has been a “complete lack of insight” into her mental health. Id. at 35. She rejects her diagnosis of schizoaffective disorder and denies a need for medication to treat that condition. A.N. told the doctor that her symptoms and problems are “of a normal spiritual nature.” Id. at 48-49. A.N. also told Dr. Martinez that she took the medication so that she could see her children, but once they turned eighteen, she would stop.

[9] On June 30, 2025, Dr. Martinez, on behalf of Fairbanks, filed an Application for Emergency Detention, asking the trial court to authorize Fairbanks to take A.N. into custody. The application alleged that A.N. had not taken her medication for several months, had sent disorganized messages through the patient portal, had deteriorating hygiene, was engaging in poor decision-making, and had become verbally aggressive. The trial court granted permission for emergency detention, ordering Fairbanks to file a request for a temporary or regular commitment within seven days of the date of admission, if needed.

[10] On July 10, 2025, Fairbanks, by Dr. Syed Hasan, filed a Petition for Commitment Hearing. Dr. Hasan asserted that A.N. suffered from schizoaffective disorder, bipolar type, was gravely disabled, and lacked insight into her illness. Dr. Hasan further asserted that A.N. was exhibiting bizarre behavior, including sending disorganized messages to her physicians. He asked the court to order that A.N. be kept in Fairbanks’ custody for a regular commitment. On July 14, 2025, after a hearing, the trial court entered an Order of Temporary Commitment not to exceed ninety days. At some point, A.N. was released to outpatient treatment. She attended monthly appointments with Dr. Martinez to check on her status and receive an injectable medication.

[11] On September 22, 2025, Fairbanks, through Dr. Martinez, filed with the trial court a report requesting extension of the temporary commitment to a regular commitment. The doctor alleged that A.N. continued to exhibit delusional thinking and that further mandatory treatment was necessary. When A.N. received notice of Dr. Martinez's request, she sent her treatment team more nonsensical messages, including “a video of a candle just melting” with no explanation. Id. at 35.

[12] The trial court held a hearing on October 9, 2025, during which Dr. Martinez, A.N.’s mother, and A.N. testified. A.N. complained that the medicine she takes drains her “energy field.” Id. at 59. She denied hallucinating but claimed that she “can see energy everywhere, like everything's fluid all the time[.]” Id. at 62. A.N. further said that she has gone to the hospital “so many times” complaining of sepsis because she feels like she's “rotting from the inside out” due to the medication. Id. at 63. Next, she said that she is part Native American, and “the head lawyer” for Duke Energy took her children away because “Duke Energy takes Lakota kids[.]” Id. at 66.

[13] A.N. denied having schizoaffective disorder, claiming that she really has depression and anxiety. She denied that she needs medication but would be willing to continue taking it until her children turn eighteen. After that point, A.N. explained, “I can see them on their own terms I don't have to keep medicated and I don't have to be supervised[.]” Id. at 70.

[14] A.N. also stated that she had a lot of emotional trauma. She expressed a willingness to see a “real forensic” therapist, but she also claimed that “no therapies will help me[.]” Id. at 66-67. She explained that the therapist would have to be able to deal with “deep space and like levels of consciousness and different dimensions[.]” Id. at 68.

[15] At the end of the hearing, the trial court granted Fairbanks’ request for a regular commitment. The court discussed the evidence showing that A.N. has a “profound lack of insight” into her mental illness and stated that A.N. was “gravely disabled as a matter of law[.]” Id. at 80.

[16] After the hearing, the trial court issued an Order of Regular Commitment. In the order, the court determined that A.N. is “gravely disabled,” as defined by statute. Appellant's App. Vol. II, p. 10. The court further stated:

[A.N.] is gravely disabled in her judgment and reasoning by schizoaffective disorder. She denies suffering from a serious, chronic mental illness and says she does not need medication, even though she has been hospitalized emergently and subjected to commitment repeatedly, most recently in late June 2025. She continues to struggle to regulate her emotions and is profoundly disorganized but has not secured a primary care doctor or a mental health therapist to address her narcolepsy or trauma. Without medication and treatment compelled by the court she will decompensate and again be unable to care for her basic needs and activities of daily living.

Id. at 12. The court ordered that A.N. is committed to Fairbanks’ care indefinitely. The court further ordered A.N. to take all medications as prescribed and to attend all clinic sessions as scheduled. This appeal followed.

Issues

[17] A.N. raises two issues, which we restate as:

I. Whether the trial court applied an incorrect standard of law.

II. Whether there is sufficient evidence to sustain the trial court's judgment.

Discussion and Decision

I. Legal Standard for Grave Disability

[18] A.N. argues that the trial court imposed an incorrect standard of law in the course of determining that she is gravely disabled. Specifically, she alleges that the trial court determined that she was gravely disabled only because she denies having schizoaffective disorder. She further alleges that she has the right to reject medical diagnoses and cannot be involuntarily committed merely for refusing treatment.

[19] We review de novo whether a trial court imposed an incorrect standard of law. See Bd. of Comm'rs of Cnty. of Vanderburgh v. Three I Props., 787 N.E.2d 967, 976 (Ind. Ct. App. 2003) (applying de novo standard to determine whether trial court applied wrong standards of law in zoning dispute). “[W]e generally presume trial courts know and follow the applicable law.” Ramsey v. Ramsey, 863 N.E.2d 1232, 1239 (Ind. Ct. App. 2007). “[T]his presumption can be overcome if the trial court's findings lead us to conclude that an unjustifiable risk exists that the trial court did not follow the applicable law.” Id.

[20] By statute, a court may involuntarily commit a person to the care of a health care provider on an emergency basis (Indiana Code section 12-26-5-1(b) (2024)); on a temporary basis not to exceed ninety days (Indiana Code section 12-26-6-1 (1992)); or on a regular, or indefinite, basis (Indiana Code section 12-26-7-5(b) (2018)).

[21] Before imposing a regular commitment, a trial court must find that the person is “mentally ill and either dangerous or gravely disabled.” I.C. § 12-26-7-5(a). The court explicitly declined to find that A.N. was dangerous. Thus, we focus on the question of grave disability. The General Assembly has defined “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.

Ind. Code § 12-7-2-96 (1992).

[22] Having reviewed the trial court's statements at the end of the evidentiary hearing and the trial court's final judgment, we reject A.N.’s claim that the court applied an incorrect standard of law. The court demonstrated that it understood and followed the statutory requirements for involuntarily committing a person for medical treatment. In addition, the trial court did not rely on only A.N.’s rejection of her diagnosis and rejection of the need for medication. Instead, the court discussed the symptoms of A.N.’s mental illness that impact her ability to meet her basic needs, including inability to regulate her emotions and unwillingness to see a therapist to address her trauma. Appellant's App. Vol. II, p. 12. A.N. has failed to rebut the presumption that the trial court applied the governing statutes.

II. Sufficiency of the Evidence

[23] A.N. next claims that Fairbanks failed to present sufficient evidence to support the trial court's determination that she is gravely disabled. “ ‘Appellate courts will affirm a civil commitment if, considering only the probative evidence and the reasonable inferences supporting it, without weighing evidence or assessing witness credibility, a reasonable trier of fact could find [the necessary elements] proven by clear and convincing evidence.’ ” A.D. v. Cmty. Fairbanks Behav. Health, 274 N.E.3d 463, 464 (Ind. 2026) (quoting J.W. v. Cmty. Fairbanks Behav. Health, 260 N.E.3d 946, 951 (Ind. 2025)). The clear and convincing evidence standard “is defined as an intermediate standard of proof greater than a preponderance of the evidence and less than proof beyond a reasonable doubt.” Commitment of B.J. v. Eskenazi Hosp./Midtown CMHC, 67 N.E.3d 1034, 1038 (Ind. Ct. App. 2016).

[24] On the specific question of grave disability, Indiana Code section 12-7-2-96, quoted above, is written in the disjunctive. As a result, “a trial court's finding of grave disability survives if we find that there was sufficient evidence to prove either that the individual was unable to provide for [her] basic needs or that [her] judgment, reasoning, or behavior was so impaired or deteriorated that it resulted in [her] inability to function independently.” Commitment of B.J., 67 N.E.3d at 1039.

[25] A.N.’s parents paid for her house. A.N.’s mother testified that when A.N. did not take her medicine, she did not keep herself or her house clean. She was also prone to angry outbursts. In addition, Dr. Martinez explained that A.N. experienced delusional thinking and disordered behavior. This is sufficient evidence that, when unmedicated, A.N. is unable to meet her basic needs and her judgment is so impaired as to prevent her from functioning independently.

[26] By the date of the evidentiary hearing, A.N.’s hygiene had improved and her symptoms had lessened. Dr. Martinez attributed these positive changes to A.N.’s enforced compliance with her medication schedule. Even so, A.N. continued to exhibit symptoms including sending nonsensical messages through the patient portal and lacking insight into her mental illness. A.N.’s testimony demonstrated continued disordered thinking, including claiming that the medicine for her mental illness had caused her to develop sepsis and accusing an energy company of taking away her children.

[27] Dr. Martinez opined that being involuntarily committed to an ongoing outpatient treatment program, which would include continuing to receive monthly injections of medication, would help A.N. to avoid relapsing into an unmedicated state, in which she would be unable to take care of herself. The doctor also stated that A.N.’s prognosis is “poor” without being committed to the program. Tr. Vol. II, p. 40. He explained that each time a person decompensates and requires hospitalization, they can suffer a decline in cognitive functioning, perhaps permanently. This evidence is sufficient to sustain the trial court's determination of grave disability. See Civil Commitment of W.S. v. Eskenazi Health, 23 N.E.3d 29, 34 (Ind. Ct. App. 2014) (finding of grave disability supported by sufficient evidence; patient denied mental illness or need for medicine despite repeated diagnoses but would be unable to meet basic needs and maintain independence without medication regimen), trans. den.

Conclusion

[28] For the reasons stated above, we affirm the judgment of the trial court.

[29] Affirmed.

FOOTNOTES

1.   The 2023 proceeding resulted in her being involuntarily committed for mental health treatment for up to ninety days. A.N. unsuccessfully appealed that judgment. A.N. v. Cmty. Health Network, Case No. 23A-MH-1658 (Ind. Ct. App. November 8, 2023) (mem.).

Baker, Senior Judge.

Vaidik, J., and Brown, J., concur.